[Federal Register Volume 75, Number 56 (Wednesday, March 24, 2010)]
[Proposed Rules]
[Pages 14288-14319]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2010-6374]
[[Page 14287]]
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Part III
Department of Energy
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10 CFR Part 430
Energy Conservation Program: Test Procedures and Standards for
Fluorescent Lamp Ballasts; Public Meeting and Availability of the
Preliminary Technical Support Document; Proposed Rules
Federal Register / Vol. 75, No. 56 / Wednesday, March 24, 2010 /
Proposed Rules
[[Page 14288]]
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DEPARTMENT OF ENERGY
10 CFR Part 430
[Docket No. EERE-2009-BT-TP-0016]
RIN 1904-AB99
Energy Conservation Program: Test Procedures for Fluorescent Lamp
Ballasts
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy.
ACTION: Notice of proposed rulemaking and public meeting.
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SUMMARY: The U.S. Department of Energy (DOE) proposes major revisions
to its test procedures for fluorescent lamp ballasts established under
the Energy Policy and Conservation Act. The proposed test method would
eliminate the use of photometric measurements in favor of purely
electrical measurements with the goal of reducing measurement
variation. DOE proposes a set of transfer functions to convert the
measured ballast electrical efficiency to a ballast efficacy factor
value. These revisions, however, do not concern the measurement of
energy consumption of ballasts in the standby and off modes, which DOE
addressed in another rulemaking. DOE also announces a public meeting to
receive comment on the issues presented in this notice.
DATES: DOE will hold a public meeting on Monday, April 26, 2010,
beginning at 9 a.m. in Washington, DC. The agenda for the public
meeting will first cover this test procedure rulemaking for fluorescent
lamp ballasts, and then the concurrent energy conservation standards
rulemaking (see proposal in today's Federal Register) for the same
products. Any person requesting to speak at the public meeting should
submit such a request, along with an electronic copy of the statement
to be given at the public meeting, before 4 p.m., Monday, April 12,
2010.
DOE will accept comments, data, and information regarding this
notice of proposed rulemaking (NOPR) before or after the public
meeting, but no later than June 7, 2010. See section V, ``Public
Participation,'' of this NOPR for details.
ADDRESSES: The public meeting will be held at the U.S. Department of
Energy, Forrestal Building, Room 8E-089, 1000 Independence Avenue, SW.,
Washington, DC 20585-0121. To attend the public meeting, please notify
Ms. Brenda Edwards at (202) 586-2945. Please note that foreign
nationals participating in the public meeting are subject to advance
security screening procedures. If a foreign national wishes to
participate in the workshop, please inform DOE of this fact as soon as
possible by contacting Ms. Brenda Edwards at (202) 586-2945 so that the
necessary procedures can be completed.
Any comments submitted must identify the Fluorescent Lamp Ballast
Active Mode Test Procedures NOPR, and provide the docket number EERE-
2009-BT-TP-0016 and/or Regulation Identifier Number (RIN) 1904-AB99.
Comments may be submitted using any of the following methods:
Federal eRulemaking Portal: http://www.regulations.gov. Follow the
instructions for submitting comments.
E-mail: [email protected]. Include the docket number
EERE-2009-BT-TP-0016 and/or RIN 1904-AB99 in the subject line of the
message.
Postal Mail: Ms. Brenda Edwards, U.S. Department of Energy,
Building Technologies Program, Mailstop EE-2J, 1000 Independence
Avenue, SW., Washington, DC, 20585-0121. Please submit one signed paper
original.
Hand Delivery/Courier: Ms. Brenda Edwards, U.S. Department of
Energy, Building Technologies Program, 6th Floor, 950 L'Enfant Plaza,
SW., Washington, DC 20024. Telephone: (202) 586-2945. Please submit one
signed paper original.
For detailed instructions on submitting comments and additional
information on the rulemaking process, see section V, ``Public
Participation,'' of this document.
Docket: For access to the docket to read background documents or
comments received, visit the U.S. Department of Energy, 6th Floor, 950
L'Enfant Plaza, SW., Washington, DC 20024, (202) 586-2945, between 9
a.m. and 4 p.m., Monday through Friday, except Federal holidays. Please
call Ms. Brenda Edwards at (202) 586-2945 for additional information
regarding visiting the Resource Room.
FOR FURTHER INFORMATION CONTACT: Ms. Linda Graves, U.S. Department of
Energy, Office of Energy Efficiency and Renewable Energy, Building
Technologies Program, EE-2J, 1000 Independence Avenue, SW., Washington,
DC 20585-0121. Telephone: (202) 586-1851. E-mail:
[email protected]. In the Office of General Counsel, contact Ms.
Betsy Kohl, U.S. Department of Energy, Office of the General Counsel,
GC-71, 1000 Independence Avenue, SW., Washington, DC 20585. Telephone:
(202) 586-7796. E-mail: [email protected].
For additional information on how to submit or review public
comments and on how to participate in the public meeting, contact Ms.
Brenda Edwards, U.S. Department of Energy, Office of Energy Efficiency
and Renewable Energy, Building Technologies Program, EE-2J, 1000
Independence Avenue, SW., Washington, DC 20585-0121. Telephone: (202)
586-2945. E-mail: [email protected].
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Authority and Background
II. Summary of the Proposal
III. Discussion
A. Scope of Applicability
1. Ballasts Covered
2. Effective Date
B. Existing Test Procedure
C. Drawbacks of Existing BEF Test Procedure
D. Efficiency Metric for Fluorescent Lamp Ballasts
E. Test Procedure Improvement Options
1. Resistor-Based Ballast Efficiency Correlated to Ballast
Efficacy Factor
2. Lamp-Based Ballast Efficiency Correlated to Ballast Efficacy
Factor
3. Improvements to Existing Test Procedure
4. Relative System Efficacy
F. Proposed Test Procedure
1. Test Conditions
2. Test Setup
3. Test Method
4. Calculations
5. Transfer Equations--General Method
6. Transfer Equations--Testing, Analysis, and Results
7. Resistor Value Determination
8. Non-Operational Ballasts When Connected to a Resistor
9. Existing Test Procedure Update
10. References to ANSI C82.2-2002
G. Burden to Conduct the Proposed Test Procedure
H. Impact on Measured Energy Efficiency
I. Certification and Enforcement
IV. Procedural Issues and Regulatory Review
A. Executive Order 12866
B. National Environmental Policy Act
C. Regulatory Flexibility Act
D. Paperwork Reduction Act
E. Unfunded Mandates Reform Act of 1995
F. Treasury and General Government Appropriations Act, 1999
G. Executive Order 13132
H. Executive Order 12988
I. Treasury and General Government Appropriations Act, 2001
J. Executive Order 13211
K. Executive Order 12630
L. Section 32 of the Federal Energy Administration Act of 1974
V. Public Participation
A. Attendance at Public Meeting
B. Procedure for Submitting Requests to Speak
C. Conduct of Public Meeting
D. Submission of Comments
E. Issues on Which DOE Seeks Comment
1. All Aspects of the Existing Test Procedure for Active Mode
Energy Consumption
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2. Appropriate Usage of ANSI Standards
3. Method of Measurement for Dimming Ballasts
4. Resistor-based Ballast Efficiency Test Method
5. Alternative Approaches to Amending the Test Procedure
6. Ballasts that do not Operate Resistors
7. Ballast Factor Variation Due to Variations in Measured Lamp
Power
8. Ballast Factor Binning
9. Transfer Equations
10. Scaling Transfer Equations
11. Burden on Manufacturers and Testing Facilities
VI. Approval of the Office of the Secretary
I. Authority and Background
Title III of the Energy Policy and Conservation Act (42 U.S.C. 6291
et seq.; EPCA or the Act) sets forth a variety of provisions designed
to improve energy efficiency. Part A of Title III (42 U.S.C. 6291-6309)
establishes the ``Energy Conservation Program for Consumer Products
Other Than Automobiles,'' which covers consumer products and certain
commercial products (all of which are referred to below as ``covered
products''), including fluorescent lamp ballasts (ballasts). (42 U.S.C.
6291(1)(2) and 6292(a)(13))
Under the Act, the overall program consists essentially of the
following parts: testing, labeling, and Federal energy conservation
standards. The testing requirements consist of test procedures,
prescribed under EPCA, that manufacturers of covered products must use
as the basis for certifying to the DOE that their products comply with
energy conservation standards adopted under EPCA and for
representations as to the efficiency of their products. Also, these
test procedures must be used whenever testing is required in an
enforcement action to determine whether covered products comply with
EPCA standards.
Section 323 of EPCA (42 U.S.C. 6293) sets forth generally
applicable criteria and procedures for DOE's adoption and amendment of
test procedures. It states, for example, that ``[a]ny test procedures
prescribed or amended under this section shall be reasonably designed
to produce test results which measure energy efficiency, energy use,* *
* or estimated annual operating cost of a covered product during a
representative average use cycle or period of use, as determined by the
Secretary [of Energy], and shall not be unduly burdensome to conduct.''
(42 U.S.C. 6293(b)(3)) In addition, if DOE determines that a test
procedure amendment is warranted, it must publish proposed test
procedures and offer the public an opportunity to present oral and
written comments on them. (42 U.S.C. 6293(b)(2)) Finally, in any
rulemaking to amend a test procedure, DOE must determine ``to what
extent, if any, the proposed test procedure would alter the measured
energy efficiency * * * of any covered product as determined under the
existing test procedure.'' (42 U.S.C. 6293(e)(1)) If DOE determines
that the amended test procedure would alter the measured efficiency of
a covered product, DOE must amend the applicable energy conservation
standard accordingly. (42 U.S.C. 6293(e)(2))
As to fluorescent lamp ballasts specifically, DOE must ``prescribe
test procedures that are in accord with ANSI \1\ standard C82.2-1984
\2\ or other test procedures determined appropriate by the Secretary.''
(42 U.S.C. 6293(b)(5)) DOE's existing test procedures for ballasts,
adopted pursuant to these and the above-described provisions, appear at
10 CFR Part 430, Subpart B, Appendix Q.
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\1\ American National Standards Institute.
\2\ ``American National Standards for Fluorescent Lamp
Ballasts--Methods of Measurement.'' Approved October 21, 1983.
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This test procedure rulemaking will fulfill the periodic review
requirement prescribed by the Energy Independence and Security Act of
2007. ``At least once every 7 years, the Secretary shall review test
procedures for all covered products and--amend test procedures with
respect to any covered product * * * or publish notice in the Federal
Register of any determination not to amend a test procedure.'' (42
U.S.C. 6293(b)(1)(A) DOE invites comment on all aspects of the existing
test procedures for fluorescent lamp ballasts for active mode energy
consumption that appear at Title 10 of the CFR Part 430, Subpart B,
Appendix Q (``Uniform Test Method for Measuring the Energy Consumption
of Fluorescent Lamp Ballasts'').
In a separate rulemaking proceeding, DOE is considering amending
energy conservation standards for fluorescent lamp ballasts (docket
number EERE-2007-BT-STD- 0016; hereinafter referred to as the
``fluorescent lamp ballast standards rulemaking''). DOE initiated that
rulemaking by publishing a Federal Register (FR) notice announcing a
public meeting and availability of the framework document (``Energy
Efficiency Program for Consumer Products: Public Meeting and
Availability of the Framework Document for Fluorescent Lamp
Ballasts,'') on January 22, 2008. 73 FR 3653. DOE has completed the
preliminary analyses for the energy conservation standard rulemaking
and published in today's Federal Register a notice announcing a public
meeting and availability of the preliminary technical support document.
On February 6, 2008, DOE held a public meeting in Washington, DC,
to discuss the framework document for the fluorescent lamp ballast
energy conservation standards rulemaking (hereinafter referred to as
the ``2008 public meeting''). At that meeting, attendees also discussed
potential revisions to the test procedure for active mode energy
consumption. All comments on the fluorescent lamp ballast standards
rulemaking regarding the measurement of active mode energy consumption
are discussed in section III of this proposed rulemaking.
DOE has also completed a standby mode and off mode test procedure.
The Energy Independence and Security Act of 2007 (Pub. L. 110-140)
amended EPCA to require that, for each covered product for which DOE's
current test procedures do not fully account for standby mode and off
mode energy consumption, DOE amend the test procedures to include
standby mode and off mode energy consumption into the overall energy
efficiency, energy consumption, or other energy descriptor for that
product. If an integrated test procedure is technically infeasible, DOE
must prescribe a separate standby mode and off mode energy use test
procedure, if technically feasible. (EPCA section 325(gg)(2)(A); 42
U.S.C. 6295(gg)(2)(A)) DOE published a final rule addressing standby
mode and off mode energy consumption for fluorescent lamp ballasts in
the Federal Register on October 22, 2009. 74 FR 54445.
II. Summary of the Proposal
In this notice of proposed rulemaking (NOPR), DOE proposes to
modify the current test procedures for fluorescent lamp ballasts to
revise the scope of applicability of this test procedure for
consistency with the ongoing fluorescent lamp ballast standards
rulemaking, improve measurement variability, and update the referenced
standards. DOE also proposes provisions for manufacturers to submit
compliance statements and certification reports for fluorescent lamp
ballasts. The following paragraphs summarize these proposed changes.
In the preliminary technical support document for the fluorescent
lamp ballast standards rulemaking, DOE makes a preliminary
determination of the scope of coverage. Today's proposed test procedure
includes specific procedures for ballasts identified in the preliminary
determination of scope. If the scope of coverage changes in the
fluorescent lamp ballast standards
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rulemaking, DOE will add or remove provisions from the test procedure
so that it is consistent with the final scope of coverage of standards.
The preliminary determination of scope includes ballasts that operate
multiple numbers of lamps (one through six), all values of ballast
factor, and many different lamp classes including 4-foot medium bipin
T8 and T12 lamps, 4-foot T5 miniature bipin lamps, 8-foot single pin
slimline T8 and T12 lamps, and 8-foot recessed double contact high
output T8 and T12 lamps. See section III.A.1 for further detail.
In addition to matching the scope of coverage for the active mode
test procedure to the scope of coverage being considered in the
fluorescent lamp ballast standards rulemaking, the proposed amendments
seek to reduce the measurement variation inherent in the existing test
procedure. The existing test procedure exhibits variation in
measurements of a similar magnitude to the spread in efficiency within
many fluorescent lamp ballast product classes analyzed in the
preliminary determination. The test measurement variation can be
attributed to reference lamp variation, lamp operation conditions, and
ballast wiring. DOE believes a test procedure with reduced variation
will allow for more precise standard setting and certification,
compliance, and enforcement testing.
DOE's proposed test method greatly reduces the impact of reference
lamps on measurement variation. The method calculates a ballast input
power and output power using only electrical measurements and resistors
that simulate the load placed on a ballast by a fluorescent lamp at a
given operating condition. Because a resistor can be manufactured with
much smaller performance tolerances than a fluorescent lamp, the
resistor introduces much less variation to the operating
characteristics of the ballast. This revised test method delivers
increased precision, thereby allowing for greater resolution. The
procedure proposed in this rulemaking measures ballast input power and
ballast output power and then calculates ballast electrical efficiency
(output power divided by input power). The ballast electrical
efficiency is then converted to ballast efficacy factor (BEF) using a
transfer equation to maintain the reported metric for energy efficiency
as BEF for consistency with use of BEF in 42 U.S.C. 6295(g)(5) and
(g)(8). DOE developed the transfer equation by measuring several
ballasts within a product class for ballast efficiency (BE) using the
proposed BE test procedure and for BEF using the existing test
procedure, and then calculating a line of best fit for the combined
data. This proposed method is hereafter referred to as the resistor-
based ballast efficiency test procedure.
Prior to selecting the proposed test method, DOE also considered
three other methods as potential improvements in the revised test
procedure: (1) The lamp-based ballast efficiency (correlated to BEF)
method, (2) the existing BEF method with revisions to reduce variation;
and (3) the relative system efficacy (RSE) method. DOE's initial
assessment of the lamp-based ballast efficiency method, which uses a
lamp as a load, rather than a resistor, indicated that, similar to the
resistor-based ballast efficiency method, there could be significant
improvements by eliminating light output-based measurements. However,
adopting that method would result in a test procedure that was still
susceptible to lamp-to-lamp variability. DOE explored the existing
light-output-based test procedure and found improvements could be made
without making fundamental changes. DOE believes that tightening
tolerances on certain specifications and clarifying loosely-defined
directions can reduce measurement variation relative to the existing
test procedure for fluorescent ballasts, but to a lesser extent than
the proposed resistor-based BE test procedure. DOE found the RSE method
to exhibit larger variation than the proposed resistor-based BE test
procedure because it uses the same measurement techniques as the
existing test procedure.
In any rulemaking to amend a test procedure, DOE must determine
``to what extent, if any, the proposed test procedure would alter the
measured energy efficiency * * * of any covered product as determined
under the existing test procedure.'' (42 U.S.C. 6293(e)(1)) If DOE
determines that the amended test procedure would alter the measured
efficiency of a covered product, DOE must amend the applicable energy
conservation standard accordingly. (42 U.S.C. 6293(e)(2)) The proposed
test procedure would change the measured energy efficiency of some
products relative to the existing test procedure. To ensure that the
standards developed in the ongoing fluorescent lamp ballast standards
rulemaking account for any changes to the test procedure, DOE is
developing the standards based on the measured energy efficiency
generated by the active mode test procedure proposed in this
rulemaking. As a result, DOE proposes an effective date for this
revised test procedure, to be published as Appendix Q1 of 10 CFR part
430 Subpart B, concurrent with the compliance date of the fluorescent
lamp ballast standards rulemaking (approximately June 30, 2014). DOE
plans to publish the final rule establishing the procedures in Appendix
Q1 in the same rule document as the final rule establishing any amended
standards.
DOE notes that ballasts that operate one or two 40 or 34 watt (W)
4-foot T12 medium bipin lamps (F40T12 and F34T12), two 75 W or 60 W 8-
foot T12 single pin slimline lamps (F96T12 and F96T12/ES); and two 110
W and 95 W 8-foot T12 recessed double contact high output lamps
(F96T12HO and F96T12HO/ES) are covered by existing energy conservation
standards. 10 CFR 430.32(m). Until the proposed effective date of the
test procedure to be published at Appendix Q1, these ballasts should
continue to be tested using the existing test procedure to determine
compliance with existing standards. DOE proposes in this NOPR to make
minor updates to the existing test procedure, published at Appendix Q
to Subpart B of part 430. DOE would update the reference to ANSI C82.2-
1984 in the existing test procedure (appendix Q) to ANSI C82.2-2002.
Because DOE does not believe the updated standard will impose increased
testing burden or alter the measured BEF of fluorescent lamp ballasts,
DOE proposes that the amendments to Appendix Q be effective 30 days
after publication of this test procedure final rule. DOE notes that
because use of the test method in Appendix Q1 is not appropriate for
those ballasts that cannot operate a resistor load bank, manufacturers
would continue to test those ballasts using the test method set forth
in Appendix Q. In addition, the test procedures for any ballasts that
operate in standby mode are also located in Appendix Q.
DOE also proposes amending the language in 10 CFR 430.62 to require
fluorescent lamp ballast manufacturers to submit compliance statements
and certification reports. This provision would also be effective 30
days after publication of this test procedure final rule. Ballast
manufacturers would begin to submit these documents to certify
compliance with existing fluorescent lamp ballast energy conservation
standards using the test procedures at Appendix Q one year following
publication of this final rule. Ballast manufacturers would certify
compliance with any amended standards using the test procedures at
Appendix Q1 beginning one year following the compliance date of the
amended standards.
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III. Discussion
A. Scope of Applicability
1. Ballasts Covered
Today's proposed test procedure is applicable to the fluorescent
lamp ballasts covered in the preliminary determination of scope
outlined in the preliminary technical support document for the
fluorescent lamp ballast standards rulemaking. The preliminary
determination of scope is as follows:
(1) Ballasts that operate one, two, three, four, five, or six
straight-shaped lamps (commonly referred to as 4-foot medium bipin
lamps) with medium bipin bases, a nominal overall length of 48
inches, a rated wattage \3\ of 25 watts (W) or more, and an input
voltage at or between 120 volts (V) and 277 V;
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\3\ The July 14, 2009 final rule establishing amended energy
conservation standard for general service fluorescent lamps and
incandescent reflector lamps (74 FR 34080) adopted a new definition
for ``rated wattage'' that can be found in 10 CFR 430.2. Please see
http://www1.eere.energy.gov/buildings/appliance_standards/residential/incandescent_lamps.html for further information.
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(2) Ballasts that operate one, two, three, four, five, or six U-
shaped lamps (commonly referred to as 2-foot U-shaped lamps) with
medium bipin bases, a nominal overall length between 22 and 25
inches, a rated wattage of 25 W or more, and an input voltage at or
between 120 V and 277 V;
(3) Ballasts that operate one or two rapid-start lamps (commonly
referred to as 8-foot high output lamps) with recessed double
contact bases, a nominal overall length of 96 inches and an input
voltage at or between 120 V and 277 V;
(4) Ballasts that operate one or two instant-start lamps
(commonly referred to as 8-foot slimline lamps) with single pin
bases, a nominal overall length of 96 inches, a rated wattage of 52
W or more, and an input voltage at or between 120 V and 277 V;
(5) Ballasts that operate one or two straight-shaped lamps
(commonly referred to as 4-foot miniature bipin standard output
lamps) with miniature bipin bases, a nominal length between 45 and
48 inches, a rated wattage of 26 W or more, and an input voltage at
or between 120 V and 277 V;
(6) Ballasts that operate one, two, three, or four straight-
shaped lamps (commonly referred to as 4-foot miniature bipin high
output lamps) with miniature bipin bases, a nominal length between
45 and 48 inches, a rated wattage of 49 W or more, and an input
voltage at or between 120 V and 277 V;
(7) Ballasts that operate one, two, three, or four straight-
shaped lamps (commonly referred to as 4-foot medium bipin lamps)
with medium bipin bases, a nominal overall length of 48 inches, a
rated wattage of 25 W or more, an input voltage at or between 120 V
and 277 V, a power factor of less than 0.90, and designed and
labeled for use in residential applications; and
(8) Ballasts that operate one, two, three, four, five, or six
rapid-start lamps (commonly referred to as 8-foot high output lamps)
with recessed double contact bases, a nominal overall length of 96
inches, an input voltage at or between 120 V and 277 V, and that
operate at ambient temperatures of 20 degrees Fahrenheit ([deg]F) or
less and are used in outdoor signs.
For the proposed test procedure in this rulemaking, DOE would
establish particular test setups and calculations depending on the
product class. When evaluating and establishing energy conservation
standards, DOE divides covered products into product classes by the
type of energy used, capacity, or other performance-related features
that affect efficiency, considering factors such as the utility of the
product to users. (See 42 U.S.C. 6295(q)) The fluorescent lamp ballast
standards rulemaking delineates product classes based on the maximum
number of lamps operated by a ballast, ballast factor, starting method,
lumen package,\4\ lamp base, market sector, and lamp length. Ballasts
contained in the same product class are subject to the same energy
conservation standards.
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\4\ Lumen package refers to the quantity of light generated by a
lamp and ballast system. For example, 8-foot RDC high output HO
lamps and 4-foot miniature bipin (MiniBP) HO lamps tend to operate
at higher currents than 8-foot single pin (SP) slimline lamps and 4-
foot MiniBP standard output (SO) lamps, respectively. This
difference in operating design increases the quantity of light per
unit of lamp length.
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At the 2008 Framework public meeting for the fluorescent lamp
ballast standards rulemaking, the Appliance Standards Awareness Project
(ASAP) asked DOE to elaborate on how the schedules for the fluorescent
lamp ballast energy conservation standard and active mode test
procedure rulemakings interact. (ASAP,\5\ Public Meeting Transcript,
No. 9 at p. 29) Because the fluorescent lamp ballast standards
rulemaking is in the preliminary analysis phase of the rulemaking
process, the proposed scope of coverage is still in draft form. To
ensure consistency in the scope of coverage, DOE plans to publish the
final rule for this test procedure rulemaking concurrently with the
ballasts standards rulemaking final rule (scheduled for June 30, 2011).
Concurrent publication affords DOE the opportunity to synchronize its
test procedure with the final scope of coverage for the fluorescent
lamp ballast standards rulemaking. If a ballast type \6\ is removed
from the scope of coverage, DOE will eliminate the pertinent test
procedures from the active mode test procedure in the final rule.
Conversely, in the event additional ballasts are added to the scope of
coverage, DOE will develop test procedures for these ballasts and
update the active mode test procedure in a subsequent rulemaking. For
example, in the preliminary analyses of the fluorescent lamp ballast
standards rulemaking, DOE's preliminary scope of coverage that does not
include ballasts capable of dimming. As DOE invites comment on this in
the fluorescent lamp ballast standards rulemaking, if DOE's final scope
of coverage includes dimming ballasts, DOE will need finalize test
procedures for these ballasts. DOE also invites comment in this test
procedure rulemaking on suggested methods of measuring the efficiency
of dimming-capable ballasts.
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\5\ A notation in the form ``ASAP, Public Meeting Transcript,
No. 9 at p. 29'' identifies a statement made in a public meeting
that DOE has received and has included in the docket of this
rulemaking. This particular notation refers to a comment: (1)
Submitted during the public meeting on February 6, 2008; (2) in
document number 9 in the docket of this rulemaking; and (3)
appearing on page 29 of the transcript.
\6\ Ballast type refers to a grouping of ballasts that use the
same starting method, and operate lamps of the same diameter, lumen
package, base type, and length. For example, instant-start ballasts
that operate 4-foot medium bipin T8 lamps.
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2. Effective Date
Because some of the test procedure amendments proposed for Appendix
Q1 will change measured efficiency and therefore affect compliance with
existing standards, DOE proposes an effective date of the revised test
procedure in Appendix Q1 to Subpart B concurrent with the compliance
date of the energy conservation standards prescribed by the fluorescent
lamp ballast standards rulemaking. DOE also plans to publish the final
rule establishing the procedures in Appendix Q1 in the same rule
document as the final rule establishing any amended standards. In the
fluorescent lamp ballast standards rulemaking, DOE is developing
standards that correspond with the active mode test procedure proposed
in this rulemaking. The proposed active mode test procedure would be
used to test ballast efficiency on or after the compliance date of the
fluorescent lamp ballast standards rulemaking (approximately June
2014). Until this compliance date, fluorescent lamp ballasts would
continue to be tested using the existing test procedure in Appendix Q
to determine compliance with existing standards. Because the
modifications to Appendix Q (an update to referenced industry
standards) do not affect the measured efficiency, DOE proposes that
they be effective 30 days after publication of this test procedure
final rule. DOE notes that because use
[[Page 14292]]
of the test method in Appendix Q1 is not appropriate for those ballasts
that cannot operate a resistor load bank, manufacturers would continue
to test those ballasts using the test method set forth in Appendix Q.
In addition, the test procedures for any ballasts that operate in
standby mode are also located in Appendix Q.
Certification and compliance procedures for fluorescent lamp
ballasts are also proposed in this rulemaking. Because these provisions
also do not affect measured efficiency, DOE proposes that they be
effective 30 days after publication of this test procedure final rule.
Accordingly, manufacturers of fluorescent lamp ballasts would be
required to submit compliance statements and certification reports to
certify compliance with existing standards, using the test procedures
at Appendix Q, one year following publication of the test procedure
final rule. Ballast manufacturers would certify compliance with any
amended standards using the test procedures at Appendix Q1 beginning
one year following the compliance date of the amended standards.
B. Existing Test Procedure
The existing ballast test procedure (in Appendix Q to Subpart B of
10 CFR part 430) used to determine the energy efficiency of a
fluorescent lamp ballast is based on light output measurements and
ballast input power. The metric used is called ballast efficacy factor
(BEF). BEF is the relative light output divided by the power input of a
fluorescent lamp ballast, as measured under test conditions specified
in ANSI standard C82.2-1984, or as may be prescribed by the Secretary.
42 U.S.C. 6291(29)(C)
The BEF metric uses light output of the lamp and ballast system
instead of ballast electrical output power in its calculation of the
efficiency of a ballast. To measure relative light output, ANSI C82.2-
1984 directs the user to measure the photocell output \7\ of the test
ballast operating a reference lamp and the light output of a reference
ballast operating the same reference lamp. Dividing photocell output of
the test ballast by the photocell output of the reference ballast
yields relative light output or ballast factor (BF). Concurrent with
measuring relative light output, the user is directed to measure
ballast input power. BEF is then calculated by dividing relative light
output by input power. A ballast that produces more light than another
ballast with the same input power will have a larger BEF.
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\7\ The photocell output of a light source is measured in units
of watts. Photocell output (watts) is one method of measuring the
light output of a light source. Through the remainder of this
document, DOE refers to the output of a fluorescent lamp as ``light
output,'' even though the existing test procedure indicates
measuring the light with photocell output.
---------------------------------------------------------------------------
C. Drawbacks of Existing BEF Test Procedure
In response to the framework document for the fluorescent lamp
ballast standards rulemaking, DOE received numerous written and verbal
comments from interested parties on the usage of ballast efficacy
factor as the metric for describing the energy consumption of
fluorescent lamp ballasts. The National Electrical Manufacturers
Association (NEMA) commented that in previous rulemakings regarding
efficiency of ballasts, the variation in BEF measurements was less of
an issue because the range of efficiency in the market was much larger.
The spread in the measured energy efficiency between magnetic and
electronic ballasts, for example, was much larger than the measurement
variation inherent to the existing test procedure. However, in the
current market, the spread in efficiency between ballasts has a much
smaller range. (NEMA, Public Meeting Transcript, No. 9 at p. 23, pp.
56-57) NEMA commented that DOE should change the metric away from BEF
because BEF measurements made in accordance with the current
fluorescent lamp ballast test procedure (appendix Q) can be shown to
have a measurement uncertainty on the order of 5 percent. NEMA stated
that when measuring the same ballast at different test laboratories
with different examples of the same reference lamp, the spread in test
results is similar to the range of T8 ballast BEFs observed in the
market today. NEMA reasoned that in order to have meaningful
verification of a standard DOE would need a metric that delineates
between the products on the market. According to NEMA, the ballast
industry would be challenged to come to consensus on a standard when so
much variation existed in the data. (NEMA, Public Meeting Transcript,
No. 9 at p. 23, pp. 35-36, pp. 56-58; NEMA,\8\ No. 11 at p. 2)
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\8\ A notation in the form ``NEMA, No. 11 at p. 2'' identifies a
written comment that DOE has received and has included in the docket
of this rulemaking or a written docket submission. This particular
notation refers to a comment: (1) Submitted by NEMA; (2) in document
number 11 in the docket of this rulemaking; and appearing on page 2.
---------------------------------------------------------------------------
DOE understands NEMA's concerns regarding the measurement
uncertainty related to the BEF measurement method under the existing
fluorescent lamp ballast test procedure. The measurement uncertainty
would negatively impact DOE's ability to set standards for ballasts, as
it could be difficult to distinguish between typical and high-
efficiency ballasts. DOE agrees with NEMA's description that the range
of efficiencies of ballasts available in the market have in general
decreased and acknowledges the need for a test method or metric that
reduces systematic error and generates more reliable test results.
Reduced variation in test procedure calculations will allow for more
precise standard setting and certification, compliance, and enforcement
testing. DOE is proposing a test procedure that is designed to reduce
systematic error and enhance energy conservation standard-setting
capabilities.
NEMA also stated that lamp manufacturing variations will create
variations in measured BEF values. (NEMA, Public Meeting Transcript,
No. 9 at p. 38; NEMA, No. 11 at p. 6; GE, Public Meeting Transcript,
No. 9 at p. 43) DOE agrees that a number of factors, in particular the
manufacturing variability of lamps, can contribute to producing this
uncertainty. Due to lamp manufacturing variability and in order to
reduce the performance variation among those lamps selected for
testing, industry standards referenced in the test procedure specify a
narrower range of operating conditions for reference lamps. ANSI C82.1-
1977 (referenced by ANSI C82.2-1984) specifies that a reference lamp
must not vary more than 2.5 percent from the lamp parameters given in
the ANSI C78 Series (1972 edition and 1975 supplement) for fluorescent
lamp electrical characteristics. Even this narrowed variation allowed
in the measured lamp power, however, has a significant impact on the
variation in BEF. Changes in measured lamp input power result in
disproportionate changes to the numerator (ballast factor) and the
denominator (input power) in the BEF metric. The percent change in
ballast factor is not as great as the percent change in ballast input
power for a given change in measured lamp input power. Consequently,
the same ballast will generate different values of BEF when tested on
reference lamps with different measured power.
GE commented that in addition to reference lamp manufacturing
variation, BEF can vary depending on the testing facility. (GE, Public
Meeting Transcript, No. 9 at p. 43) DOE agrees that deviations in test
facility environmental conditions can result in dissimilarities in
measured BEF. ANSI C82.2-1984 (incorporated in the existing test
procedure) allows ambient temperature
[[Page 14293]]
to vary 1 degrees Celsius ([deg]C) from 25 [deg]C. Through
testing, DOE has shown ambient temperature to have an effect on BEF
measurements. Specifically, DOE found that changes in ambient
temperature as small as 1 [deg]C resulted in changes in BEF as much as
1.5 percent.
NEMA commented that the BEF measurement requires photometric
measurements of a reference lamp attached to the test ballast; thus,
BEF values cannot be compared across ballasts that operate different
lamp types. A more appropriate metric would not depend on lamp
parameters or requirements. (NEMA, Public Meeting Transcript, No. 9 at
p. 38, pp. 124-125; NEMA, No. 11 at p. 6) NEMA also stated that an
alternative metric that is comparable across all instant-start or
programmed-start ballasts and capable of including lamp types yet to be
developed would be preferable to the existing test procedure using BEF.
(NEMA, Public Meeting Transcript, No. 9 at pp. 76-77, p. 99) NEMA
further commented that some lamps do not have ANSI standards governing
their operating characteristics. Considerable variation in lamp
operating conditions exists among manufacturers for these lamps because
the industry has not reached a formal consensus. (NEMA, Public Meeting
Transcript, No. 9 at pp. 76-77) NEMA suggested that DOE consider an
alternative metric based on measuring ballast input and output
electrical power as discussed in section III.E. (NEMA, Public Meeting
Transcript, No. 9 at p. 32, pp. 37-38)
DOE recognizes that BEF is not comparable across all ballasts. BEF
is measured and calculated using fluorescent lamps that vary in
measured power, thereby impacting ballast input power. As a
consequence, BEF is dependent on lamp type.\9\ DOE plans to organize
the covered ballasts into different product classes based on consumer
utility and energy efficiency differences. Because DOE will consider a
separate energy conservation standard for each of these product
classes, the test procedure must make comparisons in energy efficiency
possible within a product class. However, the existing BEF method does
not allow for such comparisons in all circumstances, as explained in
the following paragraph. DOE recognizes that comparison across product
classes may also be useful for consumers of fluorescent lamp ballasts.
DOE addresses this issue in its discussion of the resistor-based BE
method in section III.E.1.
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\9\ Lamp type describes a grouping of lamps that have the same
length, lumen package, base type, and diameter.
---------------------------------------------------------------------------
In the ongoing fluorescent lamp ballast standards rulemaking, DOE
has tentatively determined there is no distinct consumer utility
difference between T8 and T12 ballasts. As a result, DOE is considering
grouping T8 and T12 ballasts in the same product class. Due to the
difference in rated powers of the reference lamps, however, measured
BEF values for T8 and T12 ballasts are not comparable. Because DOE
plans to subject certain T8 and T12 ballasts to the same energy
conservation standard (by including these ballasts in the same product
class), DOE agrees that amendments to the existing active mode test
procedure to allow for greater comparability across lamp types is
warranted. Therefore, in this notice DOE proposes to revise the test
procedure such that the reported BEF for a T12 ballast will be
comparable to the reported BEF for a T8 ballast. These proposed
revisions are discussed in further detail in section III.F.5.
DOE also agrees that the revised test procedure and metric should
be able to encompass newly-developed lamps. The industry has not come
to consensus on operating specification standards for some of these
new, reduced-wattage lamps. Without consistent industry standards for
lamps, light-output-based testing of BEF can vary greatly. DOE proposes
to test ballasts while operating one representative load,
characterizing the lamp wattage most commonly operated. The development
and marketing of new, reduced-wattage lamps (with or without ANSI
standards) is not a concern because today's test procedure proposes to
specify a particular lamp and ballast combination for testing. See
section III.F.2 for additional detail on DOE's preliminary decision to
test ballasts while operating a load characteristic of the most common
wattage lamp.
NEMA commented that lamp filament heating introduces variability
into the existing BEF measurement (NEMA, Public Meeting Transcript, No.
9 at p. 39). DOE agrees the existing ballast test procedure is unclear
on whether or not electrode heating should be used in the reference
circuit. Electrode heating is known to increase the efficiency of a
lamp, which means the same amount of input power produces more light.
Consequently, the ballast factor of a test ballast tends to be smaller
if the reference circuit uses electrode heating compared to a reference
circuit without electrode heating. DOE agrees that the current test
procedure inserts some variability into the measurement of BF and
consequently BEF due to the apparent flexibility in the use of
reference circuit heating. In today's proposed test procedure, DOE
addresses this issue by specifying that electrode heating should always
be used in the reference circuit for medium bipin, recessed double
contact, and miniature bipin lamps. Electrode heating should not be
used in the reference circuit for single pin lamps. As discussed in
section III.E.3, DOE believes specifying whether electrode heating
should be used in the reference case limits opportunity for introducing
variation in the test procedure. DOE also understands that the
efficiency change due to electrode heating may vary from lamp to lamp.
DOE believes the variation to be relatively small, though it does not
have quantitative data to characterize this variation among lamps. DOE
invites comment on reasonable techniques to reduce this source of
variation.
NEMA also commented that filament heating should be taken into
account in comparison of ballasts with different starting methods.
(NEMA, Public Meeting Transcript, No. 9 at p. 39) DOE is aware starting
method can impact the measurement of ballast output power. Ballasts
that employ constant electrode heating generate smaller BEF values than
ballasts without constant electrode heating. Because BEF considers the
light output of a ballast, constant cathode heating tends to decrease
BEF because some of the ballast output power is used for purposes other
than light production. From a system viewpoint, however, BEF reflects
the loss in lighting efficiency due to electrode heating. Contrary to
NEMA, DOE does not believe that power dissipated by the lamp electrodes
should be included in the measurement of output power as this power is
not used directly toward the primary function of producing light. DOE
notes that it will consider setting specific standards for ballasts
that employ electrode heating based on any potential consumer utility
differences \10\ in the ongoing fluorescent lamp ballast standards
rulemaking.
---------------------------------------------------------------------------
\10\ In the fluorescent lamp ballast standards rulemaking, DOE
has tentatively determined that while rapid-start ballasts do not
offer distinct utility compared to instant-start ballasts,
programmed-start ballasts do offer distinct utility compared to
instant-start ballasts. DOE found that consumers frequently use
rapid-start ballasts as replacements for instant-start ballasts.
Programmed-start ballasts, however, can increase lamp lifetime for
frequent on/off cycling applications (e.g. for use with occupancy
sensors), providing consumer utility. Therefore, DOE has tentatively
determined to group rapid-start ballasts and instant-start ballast
in the same product class and place programmed-start ballasts in a
separate product class.
---------------------------------------------------------------------------
NEMA also indicated T8 ballasts are particularly impacted by
measurement
[[Page 14294]]
uncertainty because much of the T8 ballast market is high-frequency
electronic and T8 lamps are first operated on a low-frequency (60-
hertz) reference ballast during BEF testing. NEMA asserted that lamps
increase in efficiency when switching from low- to high-frequency
operation, but that all lamps will not gain exactly the same amount of
efficiency. NEMA mentioned it could provide data to show error of
several percent when the same ballast is tested at different labs with
different lamps due to the high-frequency to low-frequency comparison.
(NEMA, Public Meeting Transcript, No. 9 at p. 26, p. 39)
DOE agrees that random error is introduced into the measurement and
calculation of BEF due to variation in lamp efficiency gains when
switching from magnetic to electronic ballasts. In general, when a lamp
is run at high-frequency (electronic ballasts), the lamp requires less
power to produce the same amount of light when compared to a low-
frequency (magnetic) ballast. Electronic ballasts run at high
frequency, so they tend to display higher BEF values than low-frequency
magnetic ballasts. Part of this difference is due to the lamp operating
at a lower rated wattage (increased efficiency), while the remainder is
due to improvements in the electrical efficiency of the ballast. ANSI
does not specify high-frequency reference conditions for 32W F32T8, 60W
F96T12/ES, 95W F96T12HO/ES, and 110W F96T12HO fluorescent lamps.
Another source of variation in the existing test procedure is lamp
and ballast wiring for rapid- and programmed-start ballasts. These
ballasts have two wires connected to the pins on each end of the lamp.
One of the two wires supplies power to the lamp arc, and the second
provides power to the electrode. Depending on which pin the lamp arc
wire is connected to, the current supplied to the lamp arc will
encounter different amounts of resistance. The difference in resistance
is due to the position on the lamp electrode where the current starts
and finishes the lamp arc. When this position (hotspot) is in the
center of the electrode, wiring differences do not change the measured
BEF. However, when the hotspot is closer to one end or the other of the
electrode, the current encounters varied resistances based on the
distance it must travel through the electrode. Because ballast wires
are not identified as delivering energy to the lamp arc or electrode
and the position of the hotspot is unknown, this source of variation
cannot be eliminated.
At the framework document public meeting, DOE received comments
that ballast manufacturers and independent test labs use light output
measurements for calculating ballast factor for both rapid-start and
instant-start ballasts. (GE, Public Meeting Transcript, No. 9 at p. 73;
Philips, Public Meeting Transcript, No. 9 at p. 74) ANSI C82.2-1984
suggests the usage of power measurements for instant-start systems, but
common industry practice has been the usage of light output
measurements for all ballast starting methods. Ballast factor can be
calculated either as a ratio of test and reference circuit light output
or as a ratio of measured lamp power. DOE notes that power measurements
are somewhat impractical to conduct on ballasts that employ electrode
heating because these ballasts use two wires to connect to a lamp
electrode. The presence of additional wires requires more measurements
to determine output power which introduces error into the results. DOE
believes this technique introduces significant error through
capacitance to ground and loading effects on ballasts that use
electrode heating. As discussed in section III.E.3, DOE believes that
one way to reduce this error would be to require light-output
measurements to be used for all ballast types.
D. Efficiency Metric for Fluorescent Lamp Ballasts
A joint comment (hereafter the ``Joint Comment'') submitted by
ASAP, the American Council for an Energy-Efficient Economy (ACEEE), the
Alliance to Save Energy (ASE), the Natural Resources Defense Council
(NRDC), the Northeast Energy Efficiency Partnerships (NEEP), and the
Northwest Power and Conservation Council (NPCC) suggested that DOE
consider a metric other than BEF that permits comparison between
different lamp wattages, ballast types, and numbers of lamps operated
by a ballast. (Joint Comment, No. 12 at p. 1) NEMA also recommended
that DOE consider changing the metric away from BEF and toward an
alternate metric. (NEMA, No. 11 at p. 2, pp. 11-12) NEMA suggested if
DOE cannot change the metric from BEF, it should develop a test
procedure that requires the measurement of some other metric unrelated
to lamp lumen output, such as ballast efficiency \11\ or relative
system efficacy,\12\ and then give correlations to BEF so that BEF can
still be used in standard-setting. The New York State Energy Research
and Development Authority (NYSERDA) also recommended consideration of
RSE as an alternative metric. (NYSERDA, No. 9, pp. 27-28) NEMA asked if
DOE might accept a NEMA- and ANSI-supported method of measuring BE, and
correlating BE measurements with BEF values. (NEMA, Public Meeting
Transcript, No. 9 at p. 32, pp. 37-38)
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\11\ Ballast efficiency aims to capture the electrical
efficiency of a ballast by eliminating usage of lamps and
photometric measurements in the test method. Ballast efficiency
equals ballast output power divided by ballast input power. See
section III.E.4.
\12\ Relative system efficacy provides a greater range of
comparability among ballast types in comparison to ballast efficacy
factor. RSE is based on the BEF metric and creates minimal
incremental testing burden. See section III.E.4.
---------------------------------------------------------------------------
The energy conservation standard is specified using the metric of
ballast efficacy factor. 42 U.S.C. 6295(g)(5), (g)(8) In this
rulemaking, DOE proposes measuring an alternate metric (ballast
efficiency) and using a set of correlation functions so that BEF values
can be reported.
Acuity Brands Lighting also commented that much of the marketplace
(end-users, lighting designers, architects, and electrical engineers)
do not use the BEF metric and may not have knowledge of it. Acuity
Brands indicated that luminaire manufacturers are the primary users of
BEF values, using them in ballast purchasing decisions for selection of
products compliant with regulations. Acuity Brands also indicated that
a change in metric would not impact the end-user as much it may impact
luminaire manufacturers. (Acuity Brands Lighting, Public Meeting
Transcript, No. 9 at pp. 45-46) DOE understands that the lighting
design process involves metrics other than BEF. Lamp, ballast, and
luminaire combinations may be more or less efficient when analyzed as a
complete system. End-users may make their purchasing decisions from
this system viewpoint. DOE appreciates this comment; however, DOE
proposes the use of transfer equations to convert BE values to BEF for
consistency with use of the BEF metric in 42 U.S.C. 6295(g)(5) and
(g)(8).
The Joint Comment suggested that an alternate metric should account
for all power loads served by the ballast, including lamp arc power,
cathode power, and standby power consumption. (Joint Comment, No. 12 at
p. 1) DOE understands the importance of capturing all power loads
served by a fluorescent lamp ballast. DOE notes that BEF does capture
all power modes listed by the Joint Comment (lamp arc power and cathode
power) except for standby mode consumption. However, DOE does not
believe it is feasible to incorporate standby power into the BEF
metric. The BEF metric relates light
[[Page 14295]]
output (relative to a reference system) to input power. Ballasts that
produce more light using the same input wattage have a larger BEF
value. Standby mode power, however, performs a different function.
Instead of using power for light output, standby mode power is used to
facilitate activation or deactivation of other functions (active mode
functions, i.e., light output) by a remote switch. Because BEF is a
measure of light output divided by input power and not energy
consumption, DOE does not believe it is feasible to incorporate a
measure of standby mode energy use into the BEF metric for active mode
energy consumption. While DOE's preliminary determination of the scope
of coverage in the fluorescent lamp ballasts standards rulemaking does
not include ballasts capable of operating in standby mode, if the scope
of coverage changes to include these ballasts, DOE will set separate
standby mode energy conservation standards. Test procedures for the
measurement of standby mode energy consumption for fluorescent lamp
ballasts can be found in Appendix Q.
E. Test Procedure Improvement Options
Given that alternative methods of testing may result in reduced
measurement variation compared to the existing test procedure for BEF,
DOE considered three new methods for measuring the efficiency of a
ballast and one improved version of the existing method. The first
method is called the resistor-based ballast efficiency method, and
requires first measuring an estimate of ballast electrical efficiency
when operating a resistor load and then converting the estimate to BEF.
The second method, called the lamp-based ballast efficiency method,
involves measuring ballast efficiency using a lamp as the ballast load
and then converting that BE to BEF. The third method makes small
changes to the existing test procedure to improve the precision of BEF
measurement. The fourth method measures relative system efficacy, which
is a variation of ballast efficacy factor that is more comparable
across ballast types. While DOE proposes the first method to be used as
the new test procedure for determination of fluorescent lamp ballast
energy consumption, DOE is still considering all of these options for
improvement of the test procedure and therefore invites comments on all
alternative methods. The following sections discuss the merits and
drawbacks of the four methods.
1. Resistor-Based Ballast Efficiency Correlated to Ballast Efficacy
Factor
NEMA suggested at the framework document public meeting for the
fluorescent lamp ballast standards rulemaking that DOE should consider
using the BE metric. (NEMA, Public Meeting Transcript, No. 9 at p. 32,
pp. 37-38) Following the public meeting, DOE participated in the NEMA
task force on ballast efficiency through June 2009. Through a series of
conference calls and meetings, DOE learned about the resistor-based BE
method and participated in its development for four-foot 32W MBP T8
normal ballast factor ballasts. Using the data gathered and methodology
used in the NEMA task force DOE then continued development of the
proposed test procedure for other lamp types. DOE defined additional
resistor values, conducted extensive testing for both BE and BEF in
many product classes, created transfer equations so that BEF values
could be reported, and specified instrumentation specifications in its
development of the proposed test procedure.
Ballast efficiency equals lamp arc power divided by ballast input
power. Ballast efficiency aims to capture the electrical efficiency of
a ballast by eliminating usage of lamps and photometric measurements.
Instead of using a lamp and measuring light output, the resistor-based
BE method uses resistors (a resistor load bank) to simulate the lamp
and makes an electrical measurement of power through the arc-resistor.
Because a resistor can be manufactured with much smaller performance
tolerances than a fluorescent lamp, the resistor introduces much less
variation into the operating characteristics of the ballast.
NEMA commented that a BE measurement does not require lamp
electrical and photometric measurements and, thus, is both easier to
execute and more accurate. NEMA also stated that BE measurements have
lower measurement variation (on the order of 1 to 2 percent) between
test facilities and do not require ANSI standards for lamps that the
ballast is designed to operate. NEMA believes that the ballast
efficiency metric could be used to compare all ballasts of a given type
(e.g., all instant-start ballasts, all programmed-start ballasts),
regardless of the lamp types that the ballasts support (including lamp
types yet to be developed). (NEMA, Public Meeting Transcript, No. 9 at
pp. 25-27, p. 36, pp. 76-77, pp. 100-101)
DOE agrees that ballast efficiency would likely show less variation
than BEF and would allow for more equitable comparison among ballasts
operating different numbers of lamps or lamp wattages. As discussed in
section III.C, much of the variation inherent in the existing test
procedure is due to variation among reference lamps. The resistor-based
BE method reduces much of the measurement variation due to reference
lamps by using a resistor load bank to simulate the load placed on a
ballast during the measurement of input and output power. Decreased
measurement variation allows for more precise standard setting and
certification, compliance, and enforcement testing. DOE acknowledges
that the BE metric would allow for comparability across large portions
of the ballast market and that such comparability provides benefit to
consumers. DOE proposes conversion to BEF values, however, to measure
energy efficiency in a repeatable manner that provides comparison for
products in the same product class and that is also consistent with the
statutory metric set forth at 42 U.S.C. 6295(g)(5) and (g)(8).
DOE notes that use of ANSI standards would be required for lamps in
today's proposed test method because of the need to define the ballast
factor of a ballast. Ballast factor is a necessary input to the
transfer equations between BE and BEF as discussed in section III.F.5.
Because DOE proposes to test a ballast using only one lamp type,
however, new lamps without ANSI standards will not affect the test
procedure. The test procedure indicates using currently-available and
ANSI-specified lamps for the measurement and calculation of ballast
factor.
While NEMA commented that BE is the best descriptor for instant-
start energy efficiency measurements, NEMA also stated that electrode
heating effects should be taken into account for rapid-start and
programmed-start systems (NEMA, Public Meeting Transcript, No. 9 at pp.
37-39). The use of electrode heating impacts the ratio of ballast input
power to power dissipated in the lamp arc. Unlike instant-start
ballasts, programmed-start and rapid-start ballasts use a portion of
the ballast input power to heat the electrodes. Ion bombardment at the
electrode (known as sputtering) during the voltage pulse deteriorates
the lamp electrode over time. Electrode heating reduces the magnitude
of the voltage pulse required to start a lamp, thereby increasing lamp
lifetime for applications that require frequent on and off switching.
Because the resistor-based BE test method measures only the power
across the lamp arc resistor, measured output power (lamp arc power)
for ballasts such as rapid-start and some
[[Page 14296]]
programmed-start ballasts tends to be smaller than the true total
ballast output power. Instant-start ballasts are less affected by this
issue because these ballasts do not employ electrode heating. From a
lighting efficiency perspective, the BE metric captures the percentage
of input power utilized for lighting in the output stage. DOE believes
accounting for output power in this way is useful because it does
indicate that instant-start ballasts use a greater percentage of input
power in the direct production of light. The fluorescent lamp ballast
standards rulemaking will consider the impact of starting method on
consumer utility and will set energy conservation standards
accordingly.
DOE investigated the possibility of measuring the total output
power of a ballast for the BE metric to include electrode heating and
lamp arc power. To measure the total output power across the entire
resistor load bank, a user needs to measure the electrode and lamp arc
voltage separately. DOE found this measurement to introduce too much
error through capacitance to ground and loading effects on the ballast
during high-frequency operation. Accordingly, DOE has tentatively
concluded that reducing the number of measurements to ensure a more
accurate measurement is the more reasonable approach. Therefore, DOE
proposes measuring the voltage drop across the lamp arc resistor and
the input current to the resistor load bank to calculate output power
for the ballast efficiency metric.
GE commented that ballast manufacturers do not have control over
the performance of a lamp or the measurement variation associated with
the usage of reference lamps in the existing test procedure. GE noted
that the resistor-based BE metric allows ballast designers to meet a
specification that is independent of lamp variation. (GE, Public
Meeting Transcript, No. 9 at p. 43) DOE understands that ballast
designers would prefer ballast energy efficiency to be measured
independently from a lamp. DOE agrees that measured BEF is subject to
variations in measured lamp wattage and intends to reduce this source
of variation. Today's proposed test procedure reduces the effect of
reference lamp variation on variation in BEF.
DOE also believes that industry is starting to adopt BE method.
NEMA has already initiated the usage of BE in its Premium Ballast
Program, where BE is used in an alternative verification procedure.
NEMA invited DOE and other interested parties to participate in the
investigation process of the BE metric. (NEMA, Public Meeting
Transcript, No. 9 at p. 41, pp. 48-50, p. 53; NEMA, No. 11 at p. 3) In
particular, NEMA indicated that it has been studying the measurement
variation of ballast efficiency through ballast testing and wished to
collaborate directly with DOE. NEMA went on to mention that lamp
manufacturers as well as the technical coordinators for ANSI C82.11 and
the ANSI C82.11 Annex are involved and that lamp manufacturers are
aware of the BE effort and have not voiced any resistance to the
concept. (NEMA, Public Meeting Transcript, No. 9 at pp. 23-25, p. 42,
p. 45, p. 48, pp. 54-55) ASAP stated that DOE's participation could
speed the metrics replacement process and that the presence of non-
industry experts would increase ASAP's confidence in the new metric.
(ASAP, Public Meeting Transcript, No. 9 at p. 47, p. 49)
DOE participated in the NEMA task force on ballast efficiency by
taking part in conference calls, providing technical expertise, and
participating in ballast testing. NEMA measured ballast efficiency
using the resistor-based BE method through a round robin activity
(involving multiple ballast manufacturers and independent test labs)
for ballasts that operate 32W, 4-foot medium bipin T8 lamps. Using
these data, the task force honed the details of the test method and
examined the level of variation present in the data. DOE's involvement
with the NEMA task force was for the purpose of participating in round
robin testing. Once testing was complete, DOE finalized development of
today's proposed test procedure.
DOE believes the resistor-based ballast efficiency method reduces
measurement variation, in comparison to the existing test method, to a
greater extent than RSE or the improved light-output-based test
procedure. DOE prefers a test procedure with reduced variation as it
will allow for more precise standard setting and certification,
compliance, and enforcement testing. DOE invites comment on the
effectiveness of the resistor-based BE test method and its expected
improvement in measurement variation.
2. Lamp-Based Ballast Efficiency Correlated to Ballast Efficacy Factor
As an alternative to the resistor-based ballast efficiency method
(with results correlated through transfer equations to BEF) discussed
in the previous section, DOE also considered using a similar method
using a lamp (rather than a resistor load bank) as the ballast load.
This arrangement has several potential advantages over today's proposed
method. As ballasts are designed to operate lamps, not resistors,
testing the efficiency of a ballast while operating a lamp may provide
for a more accurate representation of power consumption and efficiency
than when operating a resistor. For example, a lamp is a dynamic load
which changes impedance in response to being operated at different
powers. In order to account for this effect using the resistor-based
ballast efficiency method, DOE proposes using separate resistors for
different bins of ballast factor (as discussed in section III.F.5).
Using a lamp load to test ballast efficiency, would allow manufacturers
to use a single lamp to act as the appropriate load for ballasts of all
ballast factors. Also, as discussed in section III.F.8, DOE found that
several ballasts are incompatible with the resistor-based method of
testing ballast efficiency. In order to provide a viable test procedure
for these ballasts, DOE proposes that manufacturers use the light
output-based test to measure BEF directly. Using lamp-based ballast
efficiency method could maintain a consistent testing procedure across
these ballast types. Below is a brief summary of the lamp-based ballast
efficiency (correlated to ballast efficacy factor) test method.
Similar to the resistor-based ballast efficiency method, in the
lamp-based ballast efficiency method, input and output power
measurements would be simultaneously taken by the technician while the
ballast is operating a lamp (specified by the test procedure). To
calculate ballast efficiency, the technician would divide the measured
output power by the measured input power. More specifically, a lamp
would be seasoned at least 12 hours prior to testing to ensure stable
electrical characteristics. The lamp and ballast pairing would be
selected based on DOE's determination of the most common wattage lamp a
ballast operates and the maximum number of lamps a ballast is designed
to operate. The lamp or lamps, selected for consistency with the
specifications in ANSI C78.81-2005, would be mounted in a standard
strip fixture according to ANSI C82.1-2004 and ANSI C78.81-2005.
Ballast and output power would be measured using a suitable power
analyzer and current probe. DOE would consider the same specifications
as proposed the resistor-based method as follows. Instrumentation for
current, voltage, and power measurements would be selected in
accordance with ANSI C78.375-1997 Section 9, which specifies that
instruments should be ``of the true RMS type, essentially free from
wave form
[[Page 14297]]
errors, and suitable for the frequency of operation.'' Instrument
performance could be further specified within the guidelines of the
ANSI C78.375-1997 and ANSI C82.2-2002. Specifically, current would be
measured using a galvanically isolated current probe/monitor with
frequency response between 40 Hertz (Hz) and 20 MHz. In addition,
voltage would be measured directly by a power analyzer with a maximum
100 picofarad (pF) capacitance to ground and have frequency response
between 40 Hz and 1 MHz.
Once the ballast is connected to the lamp and fixture, the ballast
would be energized at its highest rated input voltage and the lamp and
ballast system would be stabilized for up to one hour (at least fifteen
minutes) as determined in ANSI C78.375-1997. Within one hour of
energizing the ballast and after the lamp and ballast system have
stabilized, the technician would record the input power and sum of the
output powers measured for each lamp. The technician would then divide
the total output power by the input power to yield BE. Finally, if DOE
were to adopt the lamp-based BE method, similar to the resistor-based
BE method, DOE would establish correlation relationships between BE and
BEF.
While DOE recognizes the several advantages to the lamp-based BE
method (discussed earlier), DOE tentatively believes that testing for
BE using resistor load instead of a lamp load would result in reduced
measurement variation by eliminating lamp-to-lamp variability. At this
time, DOE does not have test data to support the validity of the lamp-
based BE method or for the generation of appropriate transfer equations
to correlate lamp-based BE to BEF. DOE requests additional information
on this alternative lamp-based BE method, including repeatability and
reproducibility statistics and test data. DOE also invites comment on
the burden that the lamp-based BE method imposes for testing.
3. Improvements to Existing Test Procedure
As an alternative to the ballast efficiency methods (with results
correlated through transfer equations to BEF), DOE considered modifying
certain aspects of the existing test procedure. DOE believes that some
of the measurement variation inherent in the existing test procedure
can be reduced without making fundamental changes. The measurement
variation in BEF can be attributed to operating conditions, electrode
heating in the reference circuit, variation in measured power of
reference lamps, inconsistent output power measurements in determining
ballast factor, and ambient temperature. DOE investigated methods for
improving the requirements governing these specifications.
The Illuminating Engineering Society of North America (IESNA)
Lighting Measurements Testing & Calculation Guide (LM) IESNA LM-9-1999
describes several options for operating a reference lamp. DOE believes
that the industry is not uniform in its selection of operating
conditions, which results in potential for varied BEF measurements.
Under Electrical Settings (section 8.0), IESNA LM-9-1999 states
``measurements may be taken with the lamp operating and stabilized at
the specified input volts to the reference circuit or, alternatively,
measurements may be taken with the lamp stabilized, at the rated lamp
power or at a specified current.'' These different operating conditions
can lead to varying reference ballast light outputs for the calculation
of ballast factor. For example, if the reference ballast operates the
reference lamp such that it produces less light, the ballast factor and
BEF of the test ballast will increase. If ballast operators run the
reference circuit only at the specified input voltage to the reference
circuit, DOE believes the test procedure will be more reproducible
between test facilities because only a single operating condition will
be permitted. DOE believes using the specified input voltage to the
reference circuit is the best option because it is the most common
operating condition used by industry and simplest to execute. DOE also
notes that the most recent test procedure final rule for general
service fluorescent lamps also specifies testing lamps at a constant
and specified input voltage. 74 FR 31829, 31834 (July 6, 2009).
The existing ballast test procedure is unclear as to whether
electrode heating should be used in the reference circuit. Electrode
heating is known to increase the efficiency of a lamp, which means the
same amount of input power produces more light. Compared to a reference
circuit that employs electrode heating, the ballast factor of the test
ballast tends to be larger if the reference circuit does not use
electrode heating. An issue arises when instant-start ballasts (no
electrode heating) are compared to a reference circuit that uses
electrode heating. The additional lamp efficiency in the reference
circuit decreases the ballast factor and BEF for an instant-start
ballast compared to a test method that uses no electrode heating in the
reference circuit. Although DOE acknowledges the effect on BEF due to
electrode heating in the reference circuit for instant-start test
ballasts, it notes there are no industry supported standards defining
reference circuit operating conditions for medium bipin, miniature-
bipin, and recessed double contact lamps without electrode heating.
These lamps are specified in ANSI standards according to operation with
reference ballasts using electrode heating, but instant-start, rapid-
start, or programmed-start ballasts can operate these lamps. One cannot
simply remove electrode heating from the circuit, as it would alter the
way the ballast operates the lamp. Without industry standards, DOE is
unable to quantify the effect new operating conditions might have on
ballast factor. DOE expects the effect on BEF as a result of increased
of lamp efficiency in the reference circuit to be relatively small and
consistent among all instant-start ballasts such that no particular
product is affected to a greater or lesser extent than any other
product. DOE believes that requiring electrode heating in the reference
circuit for all ballasts that operate medium bipin, miniature-bipin,
and recessed double contact lamps would limit potential variation
between test facilities.
The existing test procedure specifies that the reference lamp
electrical characteristics must not vary more than 2.5 percent from the
specifications in the ANSI C78 Series (1972 Edition and 1975
Supplement) for fluorescent lamp electrical characteristics. While this
spread in operating conditions is less than the general requirements
for the manufacturing of fluorescent lamps, it still leads to much of
the variation in ballast input power and BEF. Tightening the tolerance
on lamp electrical characteristics to 1 percent of the
specifications found in the ANSI C78 Series (1972 Edition and 1975
Supplement) would decrease measurement variation due to variability in
measured lamp power. DOE believes this change alone could result in a
large reduction in measurement variation.
Decreasing the tolerance for ambient temperature would also reduce
measurement variation. Differences in ambient temperature change the
effective load a lamp places on a ballast which affects BEF through
changes in the input power measurement. DOE found that changes in
ambient temperature as small as 1 [deg]C resulted in changes in BEF as
large as 1.5 percent. DOE believes limiting ambient temperature to 25
[deg]C 0.5 [deg]C would reduce the measurement variation
of BEF.
[[Page 14298]]
In response to the fluorescent lamp ballast standards rulemaking
framework document, DOE also received several comments related to the
ANSI standard referenced by the current fluorescent lamp ballast test
procedure. In written and verbal comments, NEMA acknowledged that ANSI
C82.2-1984 cited in the current fluorescent lamp ballast test procedure
is intended only for low-frequency ballasts and, thus, can be confusing
for technicians attempting to test high-frequency electronic ballasts.
NEMA indicated that ANSI is creating an update of ANSI C82.11-2002 and
the associated C82.11-2002 Annex (collectively known as ANSI C82.11
Consolidated-2002 \13\) that specifies an appropriate measurement
method for high-frequency electronic ballasts. (NEMA, Public Meeting
Transcript, No. 9 at pp. 71-73; NEMA, No. 11 at p. 2)
---------------------------------------------------------------------------
\13\ American National Standards for Lamp Ballasts--High
Frequency Lamp Ballasts--Supplements,'' approved January 17, 2002.
---------------------------------------------------------------------------
DOE agrees that the ANSI C82.2-1984 cited in the current test
procedure may be confusing for high-frequency ballast operation. Thus,
DOE believes updating ANSI C82.2-1984 to ANSI C82.2-2002 \14\ and
indicating the use of ANSI C82.11-2002 and ANSI C82.11 Annex would
improve the clarity of the electronic ballast test method. DOE believes
these changes would reduce measurement inconsistencies but not affect
the measured energy efficiency of the ballast. Specifically, DOE
believes the input power measurement of ANSI C82.2-2002 reduces the
interference of instrumentation on the input power measurement as
compared to ANSI C82.2-1984. DOE also believes, however, that because
modern instrumentation does not significantly interfere with input
power measurements, the differences between the input power
measurements of the two test procedures are negligible. DOE believes
ANSI C82.2-2002 should be used as the guide for measurement for both
high- and low-frequency ballasts. For ballast operating conditions, DOE
believes ANSI C82.1-2004 should be used for low-frequency (60 Hz)
ballasts and ANSI C82.11 Consolidated-2002 for high-frequency ballasts.
As discussed later in section III.F.9, while DOE is proposing to adopt
the resistor-based BE test method for compliance with any future
amended standards (using transfer equations so BEF values can be
reported), DOE also proposes updating the ANSI C82.2-1984 reference in
the existing test procedure for purposes of compliance with the
existing standards. DOE invites comment on this issue.
---------------------------------------------------------------------------
\14\ ``American National Standards for Lamp Ballasts--Method of
Measurement of Fluorescent Lamp Ballasts,'' approved June 6, 2002.
---------------------------------------------------------------------------
In the existing test procedure, ballast factor can be calculated
either as a ratio of test and reference circuit light output or as a
ratio of measured lamp power. Requiring light output measurements to be
used for all starting methods in the calculation of ballast factor
should reduce measurement variation and increase the consistency and
comparability of results. In instant-start systems, power measurements
are possible because fewer measurements are required to measure lamp
power. For programmed-start and rapid-start ballasts, two wires attach
to each end of the lamp, requiring additional voltage and current
measurements compared to the instant-start system. During high-
frequency operation, these extra measurements make it difficult to
accurately capture lamp power due to capacitance and loading effects on
the ballast. For this reason, light output measurements are used for
rapid-start and programmed-start ballasts for the measurement of
ballast factor. Although the existing test procedure indicates the
usage of power measurements for instant-start ballasts, industry
practice has been to use light output measurements for all starting
methods. DOE believes the use of light output for the measurement of
ballast factor for all ballast types would render the values of BF more
consistent between testing facilities.
Many ballasts are capable of operating lamps with different lamp
wattages. For example, a ballast designed to operate two four-foot 32W
medium bipin (MBP) T8 lamps can also operate two 30W, 28W, or 25W
lamps. The BEF will vary based on the rated wattage of the lamp
operated by the ballast. When a ballast operates a lamp with a lower
rated wattage, BEF tends to increase due to reduced ballast input
power. In an improved light-output-based test procedure, DOE would
specify particular lamp-and-ballast combinations for testing such that
a ballast is only tested while operating one specific load. DOE
believes this method would mitigate testing burden on manufacturers,
provide a representative measurement of ballast energy consumption, and
make the test procedure more flexible to new lamp-and-ballast
combinations. See section III.F.2 for additional detail on using one
lamp (resistor) and ballast combination for testing.
To test every lamp-and-ballast combination, manufacturers would
need to purchase and maintain the requisite number of reference lamps
(or in the case of the resistor-based BE method, resistors) for every
lamp wattage that a ballast can operate. In the example mentioned
above, this would require six lamps (or resistors) in addition to the
two required for the 32W lamp. For ballasts that operate more than two
lamps, the impact on manufacturers is more significant. Furthermore,
ANSI standards do not exist for every reduced wattage lamp. Because
industry has not reached a consensus regarding the performance
characteristics of each lamp, DOE did not choose a resistor to
represent those lamps for which an industry standard does not exist.
Thus, to mitigate the testing burden on manufacturers, in the
fluorescent lamp ballast standards rulemaking, DOE is considering
setting standards based on the ballast operating the most common lamp
wattage. Consequently, the test procedure only requires one lamp-and-
ballast combination to be tested in each product class. See section
III.F.2 for additional discussion on why DOE believes testing a ballast
while operating one representative load is a reasonable means of
determining the efficiency of a ballast.
Similar to lamp wattage, ballasts are designed to operate a certain
maximum number of lamps. Many ballasts can operate fewer than the
maximum number of lamps. As discussed in section III.F.2, DOE found
testing a ballast on all its possible loads (possible numbers of lamps)
was unnecessary. DOE believes requiring testing of fluorescent lamps
ballasts while operating the maximum number of lamps for which the
ballast is designed would reduce testing burden on manufacturers and
produce representative energy consumption measurements. Therefore, this
test procedure would not require testing of ballasts with every
possible number of lamps it can operate.
Some ballasts are also capable of operating at multiple input
voltages (universal voltage ballasts). The existing energy conservation
standards require ballasts to be tested at both 120 V and 277 V, which
increases the testing burden on manufacturers. The Joint Comment
suggested testing these multi-voltage ballasts at 277 V for commercial
ballasts and 120 V for residential ballasts. (Joint Comment, No. 12 at
p. 5) DOE believes that 277 V is the most common input voltage for
commercial ballasts and that 120 V is the most common for residential
ballasts. Therefore, DOE agrees with the Joint Comment and has
tentatively concluded that a revised light-output-based test procedure
should test all universal voltage commercial ballasts at 277 V and
universal voltage residential
[[Page 14299]]
ballasts at 120 V.\15\ Ballasts capable of operating only at a single
voltage would be tested at the rated ballast input voltage.
---------------------------------------------------------------------------
\15\ ANSI C82.77-2002 specifies commercial ballasts must have a
power factor greater than 0.9, while residential fluorescent
ballasts (with an input power below 120 W) must have a power factor
of 0.5 or greater. Residential ballasts are designed and labeled for
use in residential applications.
---------------------------------------------------------------------------
DOE believes the aforementioned improvements to the existing test
procedure would decrease measurement variation. Furthermore, DOE does
not believe the changes would result in significantly increased testing
burden for manufacturers. DOE believes, however, that the proposed
resistor-based BE method reduces measurement variation to a greater
extent than the improved light-output-based test procedure while also
imposing only a nominal increase in testing burden. DOE invites comment
on the effectiveness of the improved light-output-based test procedure
to reduce measurement variation and on the burden it imposes for
testing.
4. Relative System Efficacy
DOE considered the RSE metric as another alternative to the
existing BEF test procedure. The RSE metric is intended to normalize
the existing metric of BEF to rated lamp efficacy to make it more
comparable across ballasts operating different numbers of lamps and
different lamp wattages. DOE received comments suggesting use of the
RSE metric in response to the framework document for the fluorescent
lamp ballast standards rulemaking.
NEMA, NYSERDA, and the Joint Comment recommended the investigation
of RSE as a potential replacement for the BEF metric. According to
comments, the relative system efficacy metric would allow comparisons
to be made across different ballast types, thereby enabling the usage
of fewer product classes in the energy conservation standard. (NYSERDA,
Public Meeting Transcript, No. 9 at pp. 27-28, p. 75; NEMA, Public
Meeting Transcript, No. 9 at p. 100; Joint Comment, No. 12 at pp. 6-7)
Relative system efficacy is equal to BEF divided by 100 and
multiplied by total rated lamp power. RSE provides a greater range of
comparability among ballast types in comparison to BEF. Because RSE is
based on the BEF metric, it creates minimal incremental testing burden
over the existing test procedure. RSE allows for improved comparison
among ballasts designed to operate different number of lamp systems and
ballasts designed to operate different lamp wattages. Lamp and ballast
systems operating more lamps or higher-rated-wattage lamps tend to have
lower BEF values. When these lower BEF values are multiplied by
correspondingly larger total-rated-lamp powers, the resulting value is
more comparable across different product classes.
NEMA stated that it is attempting to correlate the BE and RSE
metrics to the existing BEF metric. NEMA also stated that the RSE
metric is likely to be more closely correlated to BE than the BEF
metric is to BE. (NEMA, Public Meeting Transcript, No. 9 at p. 28, p.
33) DOE believes NEMA may be correct in its prediction that RSE is more
closely correlated to BE than BEF to BE. However, DOE proposes the use
of transfer equations to convert BE values to BEF for consistency with
use of the BEF metric in 42 U.S.C. 6295(g)(5) and (g)(8). Therefore,
DOE did not consider correlating RSE to BE as an option for this
proposed test procedure.
Although the RSE metric improves on the BEF metric through
increased comparability between product classes with minimal
incremental burden, DOE believes RSE would ultimately have the same
measurement uncertainty associated with the existing test procedure or
the improved light-output based test procedure. In particular, because
RSE includes the usage of reference lamps in test measurements, RSE is
based on the same varied inputs as BEF. This rulemaking's test
procedure revision is intended to reduce measurement variation, and DOE
believes the proposed resistor-based BE method reduces measurement
variation to a greater extent than RSE. DOE invites comment on its
tentative decision not to adopt RSE as a potential test method.
F. Proposed Test Procedure
In consideration of the comments and analysis discussed above,
today's proposed test procedure for measuring active mode power
consumption is the resistor-based BE method, with results correlated to
BEF through the use of transfer equations. This method consists of the
following steps: (1) Measurement of input power to the ballast; (2)
measurement of simulated lamp arc power to estimate ballast output
power; and (3) correlation of the ballast efficiency metric to BEF. DOE
believes the resistor-based BE method results in the largest reduction
in measurement variation over the existing test procedure. Interested
parties are invited to comment on the proposed resistor-based ballast
efficiency method, the lamp-based ballast efficiency method, the
improvements to the BEF method, and the RSE method described in section
III.E, or on any other procedures they believe would be appropriate.
In the sections 1 through 8 that follow, DOE discusses the language
proposed for a new appendix Q1 to subpart B of 10 CFR part 430
(hereafter ``appendix Q1''). The new appendix Q1 will contain the new
test procedure that correlates measured BE to BEF that will be used for
the purposes of compliance with future amended standards. Section 9
describes an update to the existing test procedure in appendix Q to
subpart B of 10 CFR part 430. The change to appendix Q updates an
industry reference from ANSI C82.2-1984 to the current ANSI C82.2-2002.
DOE proposes to create a separate appendix Q1 for the proposed new test
procedure. DOE will retain the existing BEF test procedure for
compliance with existing standards and, once amended standards become
effective, for use with ballasts that cannot operate resistors. Section
10 discusses amendments DOE is proposing regarding references to ANSI
C82.2-2002.
1. Test Conditions
DOE proposes that prior to measurement, the ballasts would be
thermally conditioned at room temperature (25 [deg]C 2
[deg]C) for at least 4 hours. During this conditioning period, ballasts
are not operating or energized. Providing time for thermal conditioning
helps to generate reproducible results as electrical products'
performance characteristics tend to change in response to temperature.
In addition, DOE proposes that ballasts be tested using the
electrical supply characteristics found in section 4 of ANSI C82.2-2002
with the following changes: (1) Ballasts capable of operating at a
single voltage would be tested at the rated ballast input voltage; (2)
users of universal voltage ballasts would disregard the input voltage
directions in section 4.1 of ANSI C82.2-2002 that indicate a ballast
capable of operating at multiple voltages should be tested at both the
lowest and highest USA design center voltage; and (3) manufacturers use
the most recent revisions to the normative references associated with
ANSI C82.2-2002. Instead of testing universal voltage ballasts at the
voltages indicated in ANSI C82.2-2002, DOE believes that testing
ballasts at a single voltage is more appropriate and less burdensome.
DOE believes 277 V is the most common input voltage for commercial
ballasts and that 120 V is the most common for residential ballasts.
Therefore, DOE proposes that all universal voltage commercial ballasts
be tested at 277 V
[[Page 14300]]
and that universal voltage residential ballasts be tested at 120 V.
2. Test Setup
The resistor load bank is a network of resistors used to model the
load placed on a ballast by a fluorescent lamp. It consists of five
resistors, two for each of the two electrodes and one for the lamp arc.
In a lamp, current can arc from one electrode to the other from any two
positions (known as hotspots) on the lamp electrodes. The position can
be different each time the current flow alternates from one direction
to the other. The exact position determines the effective resistance of
the electrode by determining the distance through which current must
travel in the electrode. If the hotspots are at the ends of the
electrodes for an instant-start system, the total electrode resistance
will be greater than if the hotspots are both at the center of the
electrode. When the arc begins at the center of the electrode, the
length of the resistor is divided in half, creating a circuit with two
equivalent resistors in parallel. The hotspots' positions change over
time, but the design of the resistor load bank is limited to one fixed
position. Therefore, DOE needed to select a position for the hotspot,
and model the resistor load bank accordingly.
The selection of the hotspot position was based largely on the
design of rapid-start and programmed-start ballasts because the
position of the hotspot impacts the measured value of BE. These
ballasts use two wires to carry ballast output power to the lamp. One
of these wires supplies power for electrode heating, while the other
provides power for the lamp arc. Electrode heating requires
significantly less power than the lamp arc, so different levels of
current and voltage exist in the two ballast wires leading to the lamp.
Because these two wires are not labeled by the respective loads they
serve, the user does not know which wire is which. With two different
resistors, depending on which wire was attached to the larger or
smaller resistor, the circuit would display two different output
powers. Therefore, DOE modeled a lamp with the hotspot in the middle of
the electrode so that the resistance of each path would be equal.
Section III.F.7 describes how DOE determined resistor values for each
type of lamp.
DOE proposes that the ballast be connected to a main power source
and to the resistor load bank according to the ballast manufacturer's
wiring instructions. Where the wiring diagram indicates connecting the
ballast wire to a lamp, the lead would be connected to a resistor load
bank. Ballast wire lengths would be unaltered from the lengths supplied
by the ballast manufacturer to accurately capture the ballast
efficiency of the product in its original manufactured form. Wires
running from the load bank to the power analyzer would be kept loose or
unbundled and at a minimal working length, to reduce error introduced
to the ballast circuit because of current bypassing the ballast.
DOE also proposes that the ballast be connected to the resistor
load bank associated with the most common wattage lamp the ballast is
designed to operate. In many cases, a ballast can operate several
reduced wattage lamps in addition to the most common variety. For
example, ballasts designed to operate four-foot MBP T8 lamps can
operate 32 W, 30 W, 28 W, and 25 W lamps. Because ballasts operate
differently when connected to different loads, a single resistor load
bank is unable to simulate the load induced by all lamp wattages. To
test every lamp-and-ballast combination, manufacturers would need to
purchase and maintain the requisite number of reference lamps (or in
the case of the proposed method, resistors and lamps) for every lamp
wattage that a ballast can operate. Maintaining this number of lamps
and resistors would impose a significant burden on manufacturers.
Additionally, ANSI standards do not exist for every reduced wattage
lamp. Because industry has not reached a consensus regarding the
performance characteristics of each lamp, DOE could not choose a
resistor to represent those lamps for which an industry standard does
not exist. Thus, to mitigate the testing burden on manufacturers, the
proposed test procedure would only require one lamp-and-ballast
combination to be tested in each product class. Therefore, DOE proposes
a test procedure based on the ballast operating the most common lamp
wattage, resulting in a ballast efficiency that represents the way the
product is primarily used in the market and reducing the testing burden
on manufacturers.
DOE proposes to test fluorescent lamp ballasts operating the
maximum number of lamps for which they are designed. Many ballasts can
operate fewer than the maximum number of lamps they are designed to
operate. DOE compared the BEF of a ballast operating the maximum number
of lamps for which it was designed to a ballast operating the same
number of lamps but which was designed to operate more lamps. For
example, a 4-lamp ballast operating two lamps has a similar efficiency
to a 2-lamp ballast operating two lamps. When operating the same number
of lamps, DOE found no correlation between the ballasts capable of
operating different maximum numbers of lamps and BEF. Therefore,
today's proposed test procedure requires testing of a ballast only
while it is operating the number of resistor load banks equal to the
maximum number of lamps for which it was designed.
In response to the framework document for the fluorescent lamp
ballast standards rulemaking, the Joint Comment stated that DOE should
establish performance requirements at specific dimming levels (such as
100, 75, 50, and 25 percent) such that dimming ballasts can be
consistently compared. (Joint Comment, No. 12 at p. 5) DOE agrees that
a test procedure for dimming ballasts should specify the dimming level
or levels at which ballast efficiency should be tested. The preliminary
determination of the scope of coverage in the fluorescent lamp ballast
standards rulemaking, however, does not include dimming ballasts
because these ballasts have an overall market share of about one
percent and are already used in energy-saving systems. Thus, DOE did
not include them in the preliminary scope of coverage. If DOE
determines in the fluorescent lamp ballast standards rulemaking that
the scope of coverage should include dimming ballasts, DOE will develop
a test procedure for these ballasts. DOE invites comment on potential
methods of measurement for determining the efficiency of dimming
ballasts in the event dimming ballasts are added to the scope of
coverage in the ongoing fluorescent lamp ballast standards rulemaking.
Ballast wiring is different depending on starting method. Instant-
start ballasts have only one wire connecting the ballast to each end of
the load, while rapid-start and programmed-start ballasts have two
wires connected to each end. The second wire in rapid-start and
programmed-start systems is used for electrode heating. The resistor
load banks have two input wires connected to two electrode resistors.
In this test procedure, DOE proposes that the single output wire on an
instant-start ballast be shorted with the two input electrode resistors
to be consistent with current industry practice. DOE notes that this
circuit topology is consistent with the wiring of lamp-and-ballast
systems for bipin lamps. For example, a four-foot 32 W MBP T8 lamp has
two pins that are shorted together with the ballast output wire using a
jumper wire or an adapter. A programmed-start ballast would not need to
be shorted together because the ballast uses two wires for ballast
output between the ballast and the lamp.
[[Page 14301]]
DOE proposes that the power analyzer voltage leads be attached to
the wires leading to and from the main power source for input voltage
measurements and that the current probe be placed around the same wires
for input current. The power analyzer should have at least one channel
per lamp plus one additional channel for the ballast input power
measurement.
Figure 1 shows the instrumentation placement for the output power
measurement for ballasts that operate MBP, recessed double contact
(RDC), and miniature-bipin (miniBP) lamps and Figure 2 shows placement
for ballasts that operate single pin (SP) lamps.
[GRAPHIC] [TIFF OMITTED] TP24MR10.000
[GRAPHIC] [TIFF OMITTED] TP24MR10.001
3. Test Method
ANSI C82.2-2002 specifies operating the reference lamp with the
test ballast for less than 30 seconds to reduce the effect of lamp
restabilization on light output and to give the ballast less time to
increase in temperature. Following the protocol established in ANSI
C82.2-2002, a lamp is first stabilized on a reference ballast and then
transferred to a test ballast without being extinguished. The output of
a fluorescent lamp remains relatively constant (steady-state) when
operated under defined conditions. When these defined conditions change
(e.g., switching from a reference ballast to a test ballast) the lamp
output
[[Page 14302]]
characteristics also change. This change is not immediate, so by
limiting the time the test ballast is driving the reference lamp, the
reference lamp is kept as close as possible to its reference
conditions. In addition, as a ballast operates, it increases in
temperature until it reaches steady-state, though it may take more than
thirty minutes for a ballast to increase from room temperature to
steady-state temperature. Limiting test ballast operation to thirty
seconds limits the increase in ballast temperature. DOE believes that
over the course of thirty seconds, the change in lamp operating
characteristics has a more significant impact on light output than
changes in ballast temperature.
For the proposed resistor-based test procedure, DOE found that one
minute of operation was required to provide sufficient time to prepare
for the data capture while maintaining the ballast and resistor load
bank near room temperature. DOE recognizes that it is extending the
time of operation compared to the procedures outlined in ANSI C82.2-
2002, but it does not believe the additional 30 seconds allow for a
significant increase in temperature of the ballast or in the resistance
of the resistor load bank. As previously stated, DOE believes the main
driver in ANSI's decision to limit operation to 30 seconds was the
change in lamp operating characteristics, not ballast temperature. DOE
proposes that after one minute of data capture the ballast be switched
off, so that the resistor load bank duty cycle not exceed 50 percent
(that is, for every operational minute, the load should be rested for
one minute) to minimize any issue with thermal drift of the resistor
load bank. Thermal drift describes the phenomenon of a resistor
exhibiting a different resistance in response to a change in its
internal temperature. DOE believes that operating a resistor load bank
for one minute followed by one minute of zero power will sufficiently
reduce the opportunity for the resistor load bank deviate from its room
temperature resistance rating.
During data acquisition, the power analyzer should measure the
input voltage and current and the output voltage and current according
to the setup described in section III.F.2. DOE proposes that the
measured input parameters be voltage (RMS \16\), current (RMS), power,
and power factor measured in accordance with ANSI C82.2-2002. The
measured output parameters would include lamp arc resistor voltage,
current, and power. Instrumentation for current, voltage, and power
measurements would be selected in accordance with ANSI C78.375-1997
\17\ Section 9, which specifies that instruments should be ``of the
true RMS type, essentially free from wave form errors, and suitable for
the frequency of operation.'' DOE proposes to further specify
instrument performance within the guidelines of the ANSI C78.375-1997
and ANSI C82.2-2002. Specifically, current would be measured using a
galvanically isolated current probe/monitor with frequency response
between 40 Hertz (Hz) and 20 MHz. In addition, voltage would be
measured directly by a power analyzer with a maximum 100 picofarad (pF)
capacitance to ground and have frequency response between 40 Hz and 1
MHz.
---------------------------------------------------------------------------
\16\ Root mean square (RMS) voltage is a statistical measure of
the magnitude of a voltage signal. RMS voltage is equal to the
square root of the mean of all squared instantaneous voltages over
one complete cycle of the voltage signal.
\17\ ``American National Standard for Fluorescent Lamps--Guide
for Electrical Measurements,'' approved September 25, 1997.
---------------------------------------------------------------------------
In addition to making electrical input and output measurements,
today's proposed test procedure would also require measurement of
ballast factor for the conversion to BEF. As discussed in the ballast
factor section of III.F.5, ballast factor affects the apparent load
placed on a ballast by a lamp, and consequently the measured BEF. BF
helps assign a ballast to a particular product class, and it must be
determined empirically. DOE proposes that ballast factor be measured in
accordance with ANSI C82.2-2002 section 12, with a few modifications.
Because the measurement of ballast factor requires a reference lamp,
DOE proposes to adopt some of the improvements to the existing test
procedure described in section III.E.3. DOE believes specifying
particular electrical operating conditions, clarifying in which
circumstances electrode heating should be used in the reference
circuit, and using light output measurements instead of power
measurements for all ballasts will reduce variation in the measurement
of BF. These changes are discussed in greater detail below.
First, DOE notes that there are several options for operating a
reference lamp as described in IESNA LM-9-1999. As described in section
III.E.3, DOE proposes operating the reference lamp at the specified
input voltage to the reference circuit. This method is the simplest to
execute and the most common practice in industry. In addition, DOE
adopted this method in the test procedure final rule for general
service fluorescent lamps. 74 FR 31829, 31834 (July 6, 2009). Second,
the existing ballast test procedure is unclear on whether electrode
heating should be used in the reference circuit for all ballasts. As
described in section III.E.3, the presence or absence of electrode
heating in the reference circuit changes the light output of the
reference lamp on the reference circuit, thereby changing the measured
value of BF. DOE proposes that electrode heating be used in the
reference circuit for all ballasts that operate bipin or recessed
double contact lamps (MBP, mini-BP, RDC). Single-pin lamps should not
use heating in the reference circuit because these ballasts are not
capable of undergoing electrode heating and are designed for use with
instant-start ballasts. Third, although the existing test procedure
requires the usage of power measurements for instant-start ballasts,
industry practice has been to use light output measurements for all
starting methods. DOE proposes the use of light output for the
measurement of ballast factor for all ballast types to make the values
of BF more consistent.
In addition, because DOE is considering establishing a ballast
efficiency (correlated to BEF) test procedure based on operation of a
lamp at the most common wattage, DOE proposes that ballast factor also
be measured using the most common wattage lamp. Ballast factor should
be measured using a reference lamp with the nominal wattage indicated
in section III.F.7 for a given ballast type. This nominal wattage also
represents the type of lamp the resistor load bank simulates. Testing
each ballast with only the most common wattage lamp produces test
results that are most representative of how the end users operate
fluorescent lamp ballasts.
DOE does not believe that the usage of reference lamps for the
purpose of ballast factor determination creates significant measurement
variation. DOE believes that variations in measured lamp power affect
ballast input power to a much greater extent than ballast factor. DOE
invites comment on the variation of ballast factor due to lamp
manufacturing variations and its effect on the measurement variation of
BE converted to BEF.
4. Calculations
As described in Equation 1 below, ballast efficiency is equal to
output power divided by input power.
[GRAPHIC] [TIFF OMITTED] TP24MR10.005
DOE proposes to relate ballast efficacy factor to the measured
ballast efficiency
[[Page 14303]]
through the empirically derived transfer equations discussed in section
III.F.5.
5. Transfer Equations--General Method
A system of transfer equations is needed for correlating BE to BEF
consistent with 42 U.S.C. 6295(g). DOE determined the transfer
equations empirically by testing ballasts using both the proposed
resistor-based BE and existing BEF test methods. DOE then plotted the
results and computed a linear regression to generate an equation for
BEF as a function of BE.
The existing test procedure for fluorescent lamp ballasts allows
for ballasts to operate the reference lamps under multiple operating
modes. The user may operate at constant lamp current, voltage, or
power. DOE used constant input voltage to the reference circuits for
all of its BEF measurements and for lamp resistor determination. DOE
believes this to be the most common industry practice. Therefore, the
transfer equations that convert BE to BEF reflect this decision.
Because factors like number of lamps, ballast factor, starting
method, and lamp diameter affect the correlation between BE and BEF,
DOE considered individual transfer equations for each product class
proposed in the fluorescent lamp ballast standards rulemaking. The
following paragraphs discuss each of the factors considered in the
transfer equation development process. DOE invites comment on the
transfer equations.
Number of Lamps
The number of lamps operated by a ballast has a disparate effect on
the BE and BEF metrics. BEF decreases for ballasts operating increased
number of lamps. This is because ballast input power increases
(denominator) but the ballast factor (numerator) does not necessarily
change. In contrast, BE changes much less with varying numbers of lamps
because the numerator and denominator change by roughly proportional
amounts. Therefore, DOE parsed the data into groupings based on the
number of lamps the ballast operates. Within these groupings, DOE
plotted BE versus BEF and computed a linear regression to generate an
equation for BEF as a function of BE.
Ballast Factor
For a given ballast type, ballast factor tends to increase with
increased ballast input power. As ballast input power increases, so
does the ballast output power and consequently the light output. When a
lamp is running at a higher lamp current and power (representative of a
ballast with a high BF), lamp impedance decreases and the apparent load
the lamp places on the ballast decreases. Therefore, a high BF ballast
operating a resistor that simulates normal BF loading will measure a
higher BE than when running a load of the appropriate resistance. To
account for this change in apparent load with a resistor load bank, DOE
identified two options: (1) Modify resistor values to account for the
change in apparent load due to lamp current and BF; or (2) conduct all
testing with one resistor representing normal BF but develop separate
transfer equations for three different ranges of ballast factors
(called bins).\18\
---------------------------------------------------------------------------
\18\ DOE proposes three ballast factor bins: low, normal, and
high. Low-ballast factor ballasts have a ballast factor of 0.78 or
less; ballasts designed with a ballast factor between 0.78 and 1.10
are normal-ballast factor; and high-ballast factor ballasts were
defined to have a ballast factor of 1.10 or higher.
---------------------------------------------------------------------------
For option one, DOE would need to determine resistor values for
multiple ballast factors for each ballast type. By appropriately
matching resistance to BF, the test procedure would more accurately
model the change in apparent load as a function of ballast factor. This
method would create an additional burden on DOE at the outset of the
test procedure and an even more significant burden on manufacturers.
For example, if in order to obtain measurable improvement in testing
accuracy compared to option 2, DOE were to assign a separate resistor
value to each ballast factor in the low ballast factor product class
for 4-foot T8 MBP ballasts, DOE would need to specify four specific
resistor values. Specification of multiple resistors based on ballast
factor would require the manufacturer to purchase many more resistors
than a test procedure that used one resistor for all ballast factors.
To limit the impact on manufacturers, DOE could determine resistor
values for two to three commonly used BFs per ballast type and
establish bins around these ballast factors. Keeping the number of BF-
specific resistor values to a minimum would decrease manufacturer
burden but still be more burdensome than option 2 without offering any
appreciable improvement in testing accuracy compared to option 2.
Option two specifies that ballasts of all BFs are tested using the
same resistor value. Under this approach, ballasts designed with a
ballast factor different than the ballast factor simulated by the
resistor load bank would be operating a load that is non-representative
of the effective load placed on the ballast by a real lamp. When
testing ballasts of all ballast factors using one resistor, all else
held constant, as BF increases, measured BE will tend to increase as
well. Because the measured BE will not accurately describe lamp arc
power divided by ballast input power, DOE would need to create a
scaling technique. DOE can develop transfer equations for converting
measured BE to BEF that correspond to bins of ballast factors. Transfer
equations could be developed for particular ranges of BF so that DOE
can define different relationships between measured BE and BEF for
different BF bins. DOE proposes to use three bins because ballasts
currently offered in the market are generally centered on three
different ballast factors. DOE proposes this option because DOE
believes it appropriately balances accurate scaling based on ballast
factor with the reduced burden on manufacturers as a result of using
one resistor for all ballast factors.
DOE notes that placing ballasts into three bins based on BF results
in the measured efficiency of the ballasts with the lowest BF in a
particular bin to be relatively smaller than the higher end of the BF
bin. Low BF ballasts tend to measure a lower BE than a high BF ballast
when operating the same resistor because of the effects of current on
lamp impedance discussed previously. This could potentially encourage
the industry to produce ballasts at the upper ends of these bins, as
the associated energy conservation standard would be less stringent for
the higher BF models. DOE invites comment on this issue.
DOE considered two mitigating strategies for reducing the market
interference resulting from specifying a small number of BF bins. One
possible solution to this problem is to increase the number of BF bins
to reduce the range in BF within a bin. DOE was not able to assemble
enough data based on the ballast factors currently offered in the
market to increase the number of BF bins. The ballast market tends to
clump around two to three popular ballast factors, rendering empirical
determination of transfer equations for intermediate ballast factors
infeasible. DOE also considered creating a continuous function of BE as
a function of BF to normalize BE values for the deviation in measured
BE as a result of running a ballast on unrepresentative resistive load.
These normalized BE values would then be used as inputs to a single
transfer equation developed from data obtained by testing ballasts with
the ballast factor that the resistive load bank simulates. Similar to
efforts to increase the number of BF bins, however, DOE found that the
market provided insufficient data for scaling. With only two to three
BFs in the data
[[Page 14304]]
set, DOE could not be certain of the relationship between BF and
measured BE.
Accordingly, based upon the above considerations, DOE has
tentatively decided to proceed with option two by developing three
transfer equations relating to three different ballasts factor bins.
DOE tested ballasts of high-, normal-, and low-ballast factor varieties
for each ballast type to develop an equation for BEF as a function of
BE specific to the ballast factor type (high, normal, or low). DOE
plotted BE and BEF data for a given BF bin (high-, normal-, or low-BF
bins) and calculated a linear regression to determine an equation for
BEF as a function of BE for the given BF.
Starting Method
Starting method also impacts the correlation between BE and BEF.
Instant-start ballasts are in general more efficient than rapid-start
and programmed-start ballasts. Because instant-start ballasts do not
supply electrode heating, there are fewer losses in the ballasts'
internal circuitry and more of the output power goes to the lamp arc.
Rapid-start and programmed-start ballasts use part of their output
power to heat the lamp electrodes. In short, starting method has
nonlinear effects on the light-output-based measurement of BEF and the
BE-based measurement of BEF such that specific transfer equations are
required for each starting method. Therefore, DOE parsed the data into
groupings based on starting method. Within these groupings, DOE plotted
BE versus BEF and computed a linear regression to generate an equation
for BEF as a function of BE. In the fluorescent lamp ballast standards
rulemaking, DOE plans to consider grouping instant-start and rapid-
start ballasts in the same product class and programmed-start ballasts
in a separate product class based on consumer utility. To create BEF
values which are comparable for product classes with instant-start and
programmed-start ballasts, DOE proposes to use one transfer equation
for converting BE to BEF. This decision was made on the basis that
ballasts of the same BE should have the same BEF.
Lamp Diameter
In the fluorescent lamp ballast standards rulemaking, DOE has
tentatively determined that there is no distinct consumer utility
difference between T8 and T12 ballasts. As a result, DOE is grouping T8
and T12 ballasts in the same product class. At the 2008 public meeting,
NEMA commented that BEF measurement requires photometric measurements
of a reference lamp attached to the test ballast; thus, BEF values
cannot be compared across ballasts that operate different lamp types.
(NEMA, Public Meeting Transcript, No. 9 at pp. 124-125; NEMA, No. 11 at
p. 6) DOE agrees that under the existing test procedure, the BEF values
measured for T8 and T12 ballasts are not comparable because the
reference lamps for these ballasts have different rated power. Because
certain T8 and T12 ballasts would be subject to the same energy
conservation standard (in the preliminary analysis of the fluorescent
ballast standards rulemaking these ballasts are in the same product
class), DOE proposes to amend the test procedure such that the reported
T12 ballast BEF would be comparable to the reported BEF for a T8
ballast. To achieve this, DOE first developed transfer equations based
on data for T8 ballasts in a given product class. To generate T12
ballast BEF values which are comparable to T8 ballast BEF values, DOE
proposes using the transfer equations developed for the relevant T8
ballasts to generate a BEF for T12 ballasts. As such, a T12 ballast BE
value would be used as an input to the relevant T8 transfer equation.
The T8 transfer equation would then output a T12 ballast BEF value
comparable to BEF values for T8 ballasts. DOE made this decision based
on the assumption that T8 and T12 ballasts with the same BE should have
the same BEF when reporting compliance with energy conservations
standards.
6. Transfer Equations--Testing, Analysis, and Results
In the fluorescent lamp ballast standards rulemaking, DOE has
preliminarily categorized ballasts into 70 product classes. In today's
test procedure, DOE proposes to generate separate transfer equations
for each product class. DOE targeted representative product classes and
certain key product classes for extensive testing with the expectation
that scaling would be required to establish transfer equations for the
remaining product classes. DOE found strong correlation between BE and
BEF for the product classes indicated in Table III.1.
DOE believes a linear relationship should exist between BE and BEF
for ballasts of the same ballast factor, starting method, number of
lamps, and lamp type. All ballasts under these constraints send the
same amount of output power to a lamp, and therefore, ballasts of
different efficiency vary in input power only. A more efficient ballast
requires less input power to yield the same output power as a less
efficient ballast. Because both BE and BEF are proportional to the same
expression (the inverse of input power), a linear relationship should
exist between the two metrics. The test data indicated a linear
relationship between BE and BEF, consistent with DOE's expectation.
Although DOE tested mostly electronic ballasts, which are generally
more efficient than their magnetic counterparts, DOE believes the
linear relationship between BE and BEF should exist across all values
of BE and BEF. As such, DOE developed linear relationships between BE
and BEF such that the equation passed through the origin (a BE of zero
should correspond to a BEF of zero). DOE developed transfer equations
in the form BEF = slope * BE, establishing a slope for each product
class for the conversion of BE to BEF.
[[Page 14305]]
[GRAPHIC] [TIFF OMITTED] TP24MR10.002
Based on the test data for 4-foot 32W MBP T8 ballasts, DOE
established scaling ratios for ballast factor type, number of lamps
operated, and starting method. For ballast factor type, DOE calculated
the ratio of the slopes for product classes 2 and 14 compared to
product class 8 and used these ratios for scaling all other normal
ballast factor product classes to their high and low ballast factor
counterparts. For starting method, DOE employed a similar technique to
the ballast factor type scaling method. DOE calculated the ratio of the
slopes for product class 8 and product class 26 to establish a
relationship between the combined instant- and rapid-start ballast
product classes and the programmed-start product classes. Again, DOE
based scaling for all other combined instant- and rapid-start ballast
product classes to their programmed-start counterparts on this ratio
between instant- and rapid-start ballast and programmed-start ballasts.
For number of lamps operated by a ballast, DOE fit a power regression
equation to the slopes for 4-foot MBP T8 instant- and rapid-start
normal BF ballasts that operate one, two, or three lamps (product
classes 7, 8, and 9). DOE used the equation to extrapolate the slopes
for products classes 10, 11, and 12 (four, five, and six lamps) DOE
then used the slopes for product classes 7 through 12 to establish
ratios between the slopes for ballasts that operate 1, 3, 4, 5, or 6
lamps and the slope for ballasts that operate 2 lamps. Again, DOE based
scaling for all other 2 lamp, normal BF ballasts to their 1, 3, 4, 5,
and 6 lamp counterparts on the number of lamps ratios generated with
product classes 7 through 12.
DOE focused its testing on 4-foot 32W MBP T8 ballasts for the
establishment of scaling ratios between BF, number of lamps, and
starting method. DOE tested smaller quantities of ballasts from other
product classes, but found 8-foot T8 SP slimline ballasts to have a
strong correlation between BE and BEF in the available dataset. For 4-
foot T5 SO, 4-foot T5 HO, 8-foot RDC HO, and sign ballasts, DOE
developed a relationship between total rated lamp power and the slope
of the line relating BE to BEF. Total rated lamp power is the sum of
the rated lamp wattages (as defined in 10 CFR 430.2) operated by a
particular ballast. DOE fit a power regression equation to the slopes
and total rated input powers for product classes \19\ 7, 8, 9, 49, and
50. Using this relationship, DOE extrapolated and interpolated slopes
for product classes product
[[Page 14306]]
classes 39, 40, 43 through 46, 53, 54, and 65 through 70. DOE estimated
the slopes based on total rated lamp power for these product classes
because there was insufficient correlation in the test data to
establish a slope. DOE invites comment on its scaling technique for
number of lamps operated by a ballast, starting method, ballast factor,
and total rated lamp power.
---------------------------------------------------------------------------
\19\ Product classes are identified by numbers in Table III.1.
---------------------------------------------------------------------------
Table III.2 lists the slope of the line developed by DOE for
converting measured BE to BEF. Using the equation BEF = slope * BE,
measured BE is converted to BEF.
[GRAPHIC] [TIFF OMITTED] TP24MR10.003
7. Resistor Value Determination
The resistor-based BE method requires a resistive load bank to be
used in place of a lamp during ballast operation. Therefore, DOE
determined \20\ the resistive value corresponding to different lamp
types operating at conditions described in ANSI C78.81-2005.\21\ In
some cases, the resistor value was calculated from data published in
ANSI C78.81-2005. ANSI C78.81-2005 provides electrical characteristics
of lamps under either high-frequency or low-frequency operation. For T8
and T12 lamps, ANSI C78.81-2005 provides electrical characteristics for
low-frequency operation, and for T5 lamps, the standard provides
characteristics for high-frequency operation. Since electronic ballasts
operate in high-frequency, DOE needed to empirically determine high-
frequency resistances for testing electronic ballasts that operate T8
and T12 lamps. Since all T5 ballasts currently offered in the market
are electronic, DOE did not need to empirically determine resistor
values for low-frequency operation. DOE determined one resistor value
per lamp and did not modify the resistance based
[[Page 14307]]
on each individual different ballast factors as discussed in section
III.F.5. Table III.3 lists the resistor values determined empirically
and those specified by ANSI C78.81-2005.
---------------------------------------------------------------------------
\20\ DOE determined the simulated lamp arc resistor value at BF
= 0.88 for 4-foot 32 W MBP T8 ballasts because 0.88 was used in the
NEMA round robin and is the most common BF for this ballast type.
\21\ American National Standards for Electric Lamps, Double-
Capped Fluorescent Lamps--Dimensional and Electrical
Characteristics,'' approved August 11, 2005.
Table III.3--Simulated Lamp Resistor Values
--------------------------------------------------------------------------------------------------------------------------------------------------------
Low-frequency High-frequency
operation resistance operation resistance
Nominal (ohms) (ohms)
Ballast type lamp Lamp diameter and base -----------------------------------------------
wattage Electrode Lamp Arc Electrode Lamp Arc
(R1/2E) (Rarc) (R1/2E) (Rarc)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Ballasts that operate one, two, three, four, five, or six 32 T8 MBP........................... 5.75 439 5.75 760
straight-shaped lamps (commonly referred to as 4-foot 34 T12 MBP.......................... 4.8 151 4.8 204
medium bipin lamps) with medium bipin bases, a nominal
overall length of 48 inches, a rated wattage of 25 W or
more, and an input voltage at or between 120 V and 277 V.
Ballasts that operate one, two, three, four, five, or six 32 T8 MBP........................... 5.75 439 5.75 760
U-shaped lamps (commonly referred to as 2-foot U-shaped 34 T12 MBP.......................... 4.8 151 4.8 204
lamps) with medium bipin bases, a nominal overall length
between 22 and 25 inches, a rated wattage of 25 W or
more, and an input voltage at or between 120 V and 277 V.
Ballasts that operate one or two rapid-start lamps 86 T8 HO RDC........................ N/A N/A 4.75 538
(commonly referred to as 8-foot high output lamps) with 95 T12 HO RDC....................... 1.6 131 1.6 204
recessed double contact bases, a nominal overall length
of 96 inches and an input voltage at or between 120 V
and 277 V.
Ballasts that operate one or two instant-start lamps 59 T8............................... N/A* 876 N/A* 1256
(commonly referred to as 8-foot slimline lamps) with .......... slimline SP...................... .......... .......... .......... ..........
single pin bases, a nominal overall length of 96 inches, 60 T12.............................. N/A* 313 N/A* 431
a rated wattage of 52 W or more, and an input voltage at slimline SP......................
or between 120 V and 277 V.
Ballasts that operate one or two straight-shaped lamps 28 T5 Mini-BP....................... N/A N/A 20 950
(commonly referred to as 4-foot miniature bipin standard
output lamps) with miniature bipin bases, a nominal
length between 45 and 48 inches, a rated wattage of 26 W
or more, and an input voltage at or between 120 V and
277 V.
Ballasts that operate one, two, three, or four straight- 54 T5 Mini-BP....................... N/A N/A 4 255
shaped lamps (commonly referred to as 4-foot miniature
bipin high output lamps) with miniature bipin bases, a
nominal length between 45 and 48 inches, a rated wattage
of 49 W or more, and an input voltage at or between 120
V and 277 V.
Ballasts that operate one, two, three, or four straight- 32 T8 MBP........................... 5.75 439 5.75 760
shaped lamps (commonly referred to as 4-foot medium 34 T12 MBP.......................... 4.8 151 4.8 204
bipin lamps) with medium bipin bases, a nominal overall
length of 48 inches, a rated wattage of 25 W or more, an
input voltage at or between 120 V and 277 V, a power
factor of less than 0.90, and that are designed and
labeled for use in residential applications.
Ballasts that operate one, two, three, four, five, or six 86 T8 HO RDC........................ N/A N/A 4.75 538
rapid-start lamps (commonly referred to as 8-foot high 110 T12 HO RDC....................... 1.6 166 1.6 275
output lamps) with recessed double contact bases, a
nominal overall length of 96 inches, an input voltage at
or between 120 V and 277 V, and that operate at ambient
temperatures of 20 [deg]F or less and are used in
outdoor signs.
--------------------------------------------------------------------------------------------------------------------------------------------------------
MBP, Mini-BP, RDC, and SP represent medium bipin, miniature bipin, recessed double contact, and single pin, respectively.
* The resistor load bank representing 8-foot slimline single pin (SP) lamps does not have electrode resistors.
ANSI C78.81-2005 specifies the electrode resistance a lamp
manufacturer must achieve through design and manufacturing. Electrode
resistance is assumed to be the same for low-frequency and high-
frequency operation because a tungsten filament (lamp electrode) has
high impedance at both frequencies. For the lamp arc, the ANSI standard
provides electrical characteristics for either high or low frequency,
depending on the lamp type. By dividing lamp arc wattage by the square
of lamp current, DOE calculated the resistance of the lamp arc
resistor.
Where lamp specification sheets do not specify electrical
characteristics for the desired frequency of operation, DOE determined
resistor values empirically. DOE empirically determined resistor values
for high-frequency operation of 32 W F32T8, 60 W F96T12/ES, 95 W
F96T12HO/ES, and 110 W F96T12HO lamps. To determine the resistor values
empirically, DOE first measured the light output of a reference lamp
operated by a reference ballast at low frequency. Next, DOE connected
the same reference lamp to a reference ballast operating at high
frequency. By adjusting the voltage and current provided to the lamp,
DOE achieved the same light output for high-frequency operation as
measured in low-frequency operation. Then, DOE calculated the apparent
resistance of the lamp under high-frequency operation using measured
current and voltage.
DOE notes that the measurement of lamp arc power is slightly
different than actual lamp arc power due to the empirical method of
determining the resistor value. DOE calculated the lamp arc resistor
using measured lamp voltage and current at a predetermined
[[Page 14308]]
light output. Part of this voltage is applied across the lamp
electrodes, so the calculated lamp arc resistor value tends to be
slightly larger than reality. DOE believes the increase in calculated
lamp arc resistance due to voltage drop in the electrodes to be minimal
in comparison to the true lamp arc resistance. Because DOE cannot
measure lamp electrode resistance independently of the lamp arc, DOE
was unable to account for this problem. Design of the fluorescent lamp
prevents DOE from making this measurement. In addition, DOE does not
identify the resistance for a discrete electrode resistor for ballasts
that operate eight-foot slimline SP lamps because DOE could not
determine this value empirically and ANSI C78.81-2005 does not list the
resistance. In effect, the empirical resistor value determination
method includes the resistance of the electrodes in the resistance of
the lamp arc resistor. Because the SP lamps only have one pin, the
electrodes and lamp arc are all connected in series. When DOE measured
the resistance for the ``lamp arc resistor,'' DOE was unable to
separate the resistance of the electrodes from the lamp arc due to
design of a fluorescent lamp. While it was necessary to use electrode
resistors in medium bipin, miniature-bipin, and recessed double contact
lamps to allow for an electrode heating circuit, single-pin lamps do
not have this functionality and are only designed for use with instant-
start ballasts. Therefore, the lamp arc resistor for single-pin lamps
includes the effective resistance of the entire lamp in a single
resistor.
In addition, today's proposed high-frequency lamp arc resistor
values for ballasts that operate one, two, three, four, five, or six
straight-shaped and U-shaped lamps with medium bipin bases, a nominal
overall length of 48 inches, a rated wattage of 25 W or more, and an
input voltage at or between 120 V and 277 V are based on a ballast
factor of 0.88. This value resulted from DOE's participation in the
NEMA round robin testing for the development of the resistor-based BE
method. DOE selected a resistor for four-foot MBP ballasts that
represented a 0.88 ballast factor, which is the most common ballast
factor for this ballast type. For other ballast types, DOE used the
electrical characteristics in ANSI C78.81-2005 to develop high-
frequency lamp arc resistor values. These characteristics correspond to
a ballast factor of 1.0. DOE does not believe that the quality of the
test procedure is affected by the use of a different ballast factor for
the 4-foot T8 MBP ballasts. DOE invites comment on this issue.
8. Non-Operational Ballasts When Connected to a Resistor
During the testing process, DOE targeted certain product classes
spanning ranges of ballast factor, starting method, lamp type, and
number of lamps for extensive testing of both BEF and BE. See section
III.F.6 for additional detail on the specific product classes chosen
for testing. DOE selected several ballasts, ranging from one to
approximately fifteen, within each chosen product class and tested
three samples of each ballast. As part of its testing process for
developing transfer equations between BEF and BE, DOE identified seven
different ballast models that did not operate the resistor load bank.
Therefore, DOE was therefore unable to calculate these ballasts' BE.
These ballasts were from different product classes and different
manufacturers. In some cases, all three examples of a particular
ballast did not operate a resistor, while in the other cases only one
or two ballast examples did not operate a resistor. DOE also confirmed
that the ballasts did operate properly when connected to fluorescent
lamps. DOE does not know specifically why some ballasts do not operate
resistor load banks. It appears these ballasts sensed the load was not
a real fluorescent lamp and turned off. For ballasts found to not
operate resistors, DOE proposes that manufacturers use the existing BEF
test procedure found in appendix Q. In addition, DOE is considering an
alternative proposal in which it would include improvements to the
light-output-based test procedure in the procedure for ballasts that do
not operate resistors. DOE believes this would improve the precision of
the BEF measurements for ballasts that do not operate resistors. The
improved light-output-based test procedure could be outlined as a
separate section in Appendix Q1 only for use with ballasts that do not
operate resistors. DOE invites comment on why some ballasts do not
operate when connected to a resistor load bank.
9. Existing Test Procedure Update
As discussed in III.E.2, DOE proposes to update the reference in
the existing test procedure (appendix Q) from ANSI C82.2-1984 to ANSI
C82.2-2002, and to specify that where ANSI C82.2-2002 references ANSI
C82.1-1997, the operator shall use ANSI C82.1-2004 for testing low-
frequency ballasts and shall use ANSI C82.11-2002 for high-frequency
ballasts. These changes to the existing test procedure to modernize the
ANSI reference would be effective 30 days following publication of the
test procedure final rule. DOE does not believe the updated standard
will impose increased testing burden, nor will it alter the measured
BEF of fluorescent lamp ballasts. Because the active mode and standby
mode test procedures now both reference ANSI C82.2-2002, DOE proposes
to both update the reference and reorganize the test procedure outlined
in appendix Q for clarity.
10. References to ANSI C82.2-2002
As stated, in this NOPR DOE is proposing amendments to the
fluorescent lamp ballast test procedure that would incorporate
references to ANSI C82.2-2002 into appendix Q and appendix Q1. In
examining the ANSI standard, DOE found that within ANSI C82.2-2002
there are references other ANSI standards. In particular, section 2 of
ANSI C82.2-2002 states that ``when American National Standards referred
to in this document [ANSI C82.2-2002] are superseded by a revision
approved by the American National Standards Institute, Inc. the
revision shall apply.'' Revisions to these normative standards could
potentially impact compliance with energy conservation standards by
changing the tested value for energy efficiency. Therefore, DOE
proposes to specify the particular versions of the ANSI standards that
would be used in conjunction with ANSI C82.2-2002. DOE proposes to use
ANSI C78.81-2005, ANSI C78.901-2005, ANSI C82.1-2004, ANSI C82.11-2002,
and ANSI C82.13-2002 in support of ANSI C82.2-2002. All other normative
references would be as directly specified in ANSI C82.2-2002. These
specifications would apply to the ANSI C82.2-2002 references in
Appendix Q and to the ANSI C82.2-2002 references in Appendix Q1. DOE
conducted testing in development of today's proposed test procedure for
Appendix Q1 in accordance with the aforementioned industry references.
G. Burden To Conduct the Proposed Test Procedure
EPCA requires that ``[a]ny test procedures prescribed or amended
under this section shall be reasonably designed to produce test results
which measure energy efficiency, energy use * * * or estimated annual
operating cost of a covered product during a representative average use
cycle or period of use * * * and shall not be unduly burdensome to
conduct.'' (42 U.S.C. 6293(b)(3)). Today's proposed test procedure
seeks to calculate the efficiency of a ballast by computing the
[[Page 14309]]
ratio of ballast output power (simulated lamp arc power) to ballast
input power. This ratio is then converted to ballast efficacy factor,
the statutorily required efficiency metric. DOE believes its proposed
method minimizes burden on manufacturers while still achieving an
effective test procedure.
DOE sought to reduce manufacturer burden wherever possible. As
described in section III.F.2, DOE chose to test each ballast type using
only one resistor load bank instead of using a different load for each
ballast factor and number of lamps associated with a ballast. DOE
believes this choice reduces burden on the manufacturer. In addition,
the proposed test procedure requires no additional measurement
instrumentation beyond what ballast manufacturers use for the existing
test procedure and other general uses. The required measurement of
ballast factor is no different than the procedure manufacturers already
use for reporting BF in their literature. The use of resistors for
measuring ballast input power and lamp arc power, however, does impose
a small incremental burden compared to the existing test procedure. DOE
estimates the initial purchase cost of resistors for a two-lamp ballast
to be about $1000 to $2000 and does not believe this additional
materials burden is unreasonable due to the low cost and the fact that
the materials cost can be amortized over the span of many years because
the resistors maintain integrity over a long lifespan. The test
procedure imposes a minimal incremental labor burden of about 30 to 60
minutes for a two-lamp ballast over the existing test procedure to
measure BE using the ballast-resistor setup. For these reasons, even
for small ballast manufacturers, DOE believes the testing burden is not
unduly burdensome. DOE invites comment on this issue.
H. Impact on Measured Energy Efficiency
In any rulemaking to amend a test procedure, DOE must determine
``to what extent, if any, the proposed test procedure would alter the
measured energy efficiency * * * of any covered product as determined
under the existing test procedure.'' (42 U.S.C. 6293(e)(1)) If DOE
determines that the amended test procedure would alter the measured
efficiency of a covered product, DOE must amend the applicable energy
conservation standard accordingly. (42 U.S.C. 6293(e)(2)) This proposed
active mode test procedure does impact the reported BEF value. Some
products will test with higher or lower efficiency based on the new
test procedure because of the transfer equation between the measured
parameters and the reported BEF value. DOE is currently amending energy
conservation standards for fluorescent lamp ballasts in the fluorescent
lamp ballast standards rulemaking. In that rulemaking, DOE will
consider standards based on the measured efficiency of the ballast in
accordance with the test procedure proposed in this active mode test
procedure rulemaking consistent with 42 U.S.C. 6293(e)(2). DOE will use
test data that it collects in the course of both this test procedure
rulemaking and the fluorescent lamp ballast standards rulemaking when
setting energy conservation standards for fluorescent lamp ballasts.
I. Certification and Enforcement
Ballast manufacturers are currently not required to submit
compliance statements and certification reports. In this rulemaking,
DOE proposes to require fluorescent lamp ballast manufacturers to
follow the certification and enforcement requirements summarized in
subpart F of 10 CFR part 430.
DOE regulations at 10 CFR 430.62(a)(4) describe the format and
content of a certification report for consumer products. DOE proposes
to include fluorescent lamp ballasts in the list of products for which
certification reports are required (along with specific energy
consumption metrics). The revised submission of data section will
indicate that ballast manufacturers should report ballast efficacy
factor and power factor in certification reports. The definition of
``basic model'' can be found at 10 CFR 430.2; the fluorescent lamp
ballast test procedure can be found in 10 CFR part 430, subpart B,
Appendix Q, and the sampling plan can be found at 10 CFR 430.24(q).
Manufacturers would be required to follow all other provisions of
subpart F of 10 CFR part 430 for certification and enforcement
applicable to all covered ballasts.
DOE proposes that certification statements and compliance reports
be submitted in accordance with the existing energy conservation
standards one year after publication of this rulemaking (publication
approximately June 30, 2011). In addition, DOE proposes that
certification statements and compliance reports be submitted in
accordance with the revised energy conservation standards and possible
expansion of scope of coverage one year after these standards become
effective (effective date of standards approximately June 30, 2014).
IV. Procedural Issues and Regulatory Review
A. Executive Order 12866
Today's proposed rule has been determined to not be a ``significant
regulatory action'' under Executive Order 12866, ``Regulatory Planning
and Review,'' 58 FR 51735 (Oct. 4, 1993). Accordingly, this action was
not subject to review under that Executive Order by the Office of
Information and Regulatory Affairs (OIRA) of the Office of Management
and Budget (OMB).
B. National Environmental Policy Act
In this proposed rule, DOE proposes test procedure amendments that
it expects will be used to develop and implement future energy
conservation standards for ballasts. DOE has determined that this rule
falls into a class of actions that are categorically excluded from
review under the National Environmental Policy Act of 1969 (42 U.S.C.
4321 et seq.) and DOE's implementing regulations at 10 CFR part 1021.
Specifically, this proposed rule would amend the existing test
procedures without affecting the amount, quality or distribution of
energy usage, and, therefore, would not result in any environmental
impacts. Thus, this rulemaking is covered by Categorical Exclusion A5
under 10 CFR part 1021, subpart D, which applies to any rulemaking that
interprets or amends an existing rule without changing the
environmental effect of that rule. Accordingly, neither an
environmental assessment nor an environmental impact statement is
required.
C. Regulatory Flexibility Act
The Regulatory Flexibility Act (5 U.S.C. 601 et seq.) requires
preparation of an initial regulatory flexibility analysis for any rule
that by law must be proposed for public comment, unless the agency
certifies that the rule, if promulgated, will not have a significant
economic impact on a substantial number of small entities. As required
by Executive Order 13272, ``Proper Consideration of Small Entities in
Agency Rulemaking,'' 67 FR 53461 (August 16, 2002), DOE published
procedures and policies on February 19, 2003, to ensure that the
potential impacts of its rules on small entities are properly
considered during the DOE rulemaking process. 68 FR 7990. DOE has made
its procedures and policies available on the Office of the General
Counsel's Web site: http://www.gc.doe.gov.
The Small Business Administration (SBA) has set size thresholds for
[[Page 14310]]
manufacturers of fluorescent lamp ballasts that define those entities
classified as ``small businesses'' for the purposes of the RFA. DOE
used the SBA's small business size standards to determine whether any
small manufacturers of fluorescent lamp ballasts would be subject to
the requirements of the rule. 65 FR 30836, 30850 (May 15, 2000), as
amended at 65 FR 53533, 53545 (September 5, 2000) and codified at 13
CFR part 121. The size standards are listed by North American Industry
Classification System (NAICS) code and industry description and are
available at http://www.sba.gov/idc/groups/public/documents/sba_homepage/serv_sstd_tablepdf.pdf. Fluorescent lamp ballast
manufacturing is classified under NAICS 335311, Power, Distribution, &
Specialty Transformer Manufacturing. The SBA sets a threshold of 750
employees or less for an entity to be considered as a small business
for this category.
To better assess the potential impacts of the proposed standards
for fluorescent lamp ballasts on small entities, DOE conducted a more
focused inquiry of the companies that could be small manufacturers of
fluorescent lamp ballasts. During its market survey, DOE used all
available public information to identify potential small manufacturers.
DOE's research involved several industry trade association membership
directories, product databases, individual company Web sites, and
marketing research tools (e.g., Dunn and Bradstreet reports) to create
a list of every company that manufactures or sells fluorescent lamp
ballasts covered by this rulemaking. DOE reviewed all publicly-
available data and contacted select companies on its list, as
necessary, to determine whether they met the SBA's definition of a
small business manufacturer of covered fluorescent lamp ballasts. DOE
screened out companies that did not offer fluorescent lamp ballasts
covered by this rulemaking, did not meet the definition of a ``small
business,'' or are foreign owned and operated. Ultimately, DOE
identified approximately 15 fluorescent lamp ballast manufacturers that
produce covered fluorescent lamp ballasts and can potentially be
considered small businesses.
The proposed rule includes revisions to appendix Q and appendix Q1,
as well as certification reporting requirements. The revisions to
appendix Q update an industry reference and do not change the test
method or increase testing burden. The only difference between the two
test procedures relates to the interference of testing instrumentation.
Specifically, the input power measurement of ANSI C82.2-2002 reduces
the interference of instrumentation on the input power measurement as
compared to ANSI C82.2-1984. The vast majority of companies and testing
facilities, however, already employ modern instrumentation that does
not significantly interfere with input power measurements. Thus,
updating this industry reference would not impose additional financial
burden in terms of labor or materials. The proposed test procedure in
appendix Q1 imposes a minimal incremental burden compared to the
existing test procedure and industry practices. For a 2-lamp ballast,
the new procedure requires a small increase in the labor burden of 30
to 60 minutes and a relatively small increase in materials costs ($1000
to $2000 initial purchase price). Finally, DOE estimates that the
proposed certification reporting requirements would average 30 hours
per response.
To analyze the testing burden impacts described above on small
business manufacturers, DOE identified small business manufacturers of
fluorescent lamp ballasts included in the preliminary scope of coverage
considered in the fluorescent lamp ballast standards rulemaking as
described above. DOE sought to examine publically available financial
data for these companies to compare revenue and profit to the
anticipated testing burden associated with this proposed test
procedure. DOE determined that all the identified small business
manufacturers were privately owned, and as a result, financial data was
not publically available. Instead, DOE estimated testing burden for a
small business with 0.1 percent market share of covered fluorescent
lamp ballasts and revenue of approximately one million dollars. DOE
assumed that this small manufacturer would sell approximately 30 basic
models of a single ballast type. Based on the assumptions stated in the
previous paragraphs, DOE estimated that the annual testing costs for
this small business would be about $10,000, constituting 1 percent of
annual revenue. Including the 30 hours per response for certification
reporting, DOE believes this to be a small percentage of revenue and
not a significant impact.
On the basis of the foregoing, DOE tentatively concludes and
certifies that this proposed rule would not have a significant impact
on a substantial number of small entities. Accordingly, DOE has not
prepared a regulatory flexibility analysis for this rulemaking. DOE
will provide its certification and supporting statement of factual
basis to the Chief Counsel for Advocacy of the Small Business
Administration for review under 5 U.S.C. 605(b).
D. Paperwork Reduction Act
This rule contains a collection-of-information requirement subject
to the Paperwork Reduction Act (PRA) which has been approved by OMB
under control number 1910-1400. Public reporting burden for compliance
reporting for energy and water conservation standards is estimated to
average 30 hours per response, including the time for reviewing
instructions, searching existing data sources, gathering and
maintaining the data needed, and completing and reviewing the
collection of information. Send comments regarding this burden
estimate, or any other aspect of this data collection, including
suggestions for reducing the burden, to DOE (see ADDRESSES) and by e-
mail to [email protected].
Notwithstanding any other provision of the law, no person is
required to respond to, nor shall any person be subject to a penalty
for failure to comply with, a collection of information subject to the
requirements of the PRA, unless that collection of information displays
a currently valid OMB Control Number.
E. Unfunded Mandates Reform Act of 1995
Title II of the Unfunded Mandates Reform Act of 1995 (UMRA) (Pub.
L. 104-4) requires each Federal agency to assess the effects of Federal
regulatory actions on State, local, and Tribal governments and the
private sector. For proposed regulatory actions likely to result in a
rule that may cause expenditures by State, local, and Tribal
governments, in the aggregate, or by the private sector of $100 million
or more in any one year (adjusted annually for inflation), section 202
of UMRA requires a Federal agency to publish estimates of the resulting
costs, benefits, and other effects on the national economy. (2 U.S.C.
1532(a), (b)) UMRA also requires Federal agencies to develop an
effective process to permit timely input by elected officers of State,
local, and Tribal governments on a proposed ``significant
intergovernmental mandate.'' In addition, UMRA requires an agency plan
for giving notice and opportunity for timely input to small governments
that may be affected before establishing a requirement that might
significantly or uniquely affect them. On March 18, 1997, DOE published
a statement of policy on its process for intergovernmental consultation
under UMRA. 62 FR 12820. (This policy is
[[Page 14311]]
also available at http://www.gc.doe.gov). Today's proposed rule
contains neither an intergovernmental mandate, nor a mandate that may
result in the expenditure of $100 million or more in any year, so these
requirements do not apply.
F. Treasury and General Government Appropriations Act, 1999
Section 654 of the Treasury and General Government Appropriations
Act, 1999 (Pub. L. 105-277) requires Federal agencies to issue a Family
Policymaking Assessment for any proposed rule that may affect family
well-being. Today's proposed rule would not have any impact on the
autonomy or integrity of the family as an institution. Accordingly, DOE
has concluded that it is unnecessary to prepare a Family Policymaking
Assessment.
G. Executive Order 13132
Executive Order 13132, ``Federalism,'' 64 FR 43255 (August 4, 1999)
imposes certain requirements on agencies formulating and implementing
policies or regulations that preempt State law or that have Federalism
implications. The Executive Order requires agencies to examine the
constitutional and statutory authority supporting any action that would
limit the policymaking discretion of the States and to carefully assess
the necessity for such actions. The Executive Order also requires
agencies to have an accountable process to ensure meaningful and timely
input by State and local officials in the development of regulatory
policies that have Federalism implications. On March 14, 2000, DOE
published a statement of policy describing the intergovernmental
consultation process it will follow in the development of such
regulations. 65 FR 13735. DOE has examined this proposed rule and has
determined that it would not have a substantial direct effect on the
States, on the relationship between the national government and the
States, or on the distribution of power and responsibilities among the
various levels of government. EPCA governs and prescribes Federal
preemption of State regulations as to energy conservation for the
products that are the subject of today's proposed rule. States can
petition DOE for exemption from such preemption to the extent, and
based on criteria, set forth in EPCA. (42 U.S.C. 6297(d)) No further
action is required by Executive Order 13132.
H. Executive Order 12988
With respect to the review of existing regulations and the
promulgation of new regulations, section 3(a) of Executive Order 12988,
``Civil Justice Reform,'' 61 FR 4729 (Feb. 7, 1996), imposes on Federal
agencies the general duty to adhere to the following requirements: (1)
Eliminate drafting errors and ambiguity; (2) write regulations to
minimize litigation; (3) provide a clear legal standard for affected
conduct rather than a general standard; and (4) promote simplification
and burden reduction. Section 3(b) of Executive Order 12988
specifically requires that Executive agencies make every reasonable
effort to ensure that the regulation: (1) Clearly specifies the
preemptive effect, if any; (2) clearly specifies any effect on existing
Federal law or regulation; (3) provides a clear legal standard for
affected conduct while promoting simplification and burden reduction;
(4) specifies the retroactive effect, if any; (5) adequately defines
key terms; and (6) addresses other important issues affecting clarity
and general draftsmanship under any guidelines issued by the Attorney
General. Section 3(c) of Executive Order 12988 requires Executive
agencies to review regulations in light of applicable standards in
sections 3(a) and 3(b) to determine whether they are met or it is
unreasonable to meet one or more of them. DOE has completed the
required review and determined that, to the extent permitted by law,
the proposed rule meets the relevant standards of Executive Order
12988.
I. Treasury and General Government Appropriations Act, 2001
Section 515 of the Treasury and General Government Appropriations
Act, 2001 (Pub. L. 106-554; 44 U.S.C. 3516 note) provides for agencies
to review most disseminations of information to the public under
guidelines established by each agency pursuant to general guidelines
issued by OMB. OMB's guidelines were published at 67 FR 8452 (Feb. 22,
2002), and DOE's guidelines were published at 67 FR 62446 (Oct. 7,
2002). DOE has reviewed today's proposed rule under the OMB and DOE
guidelines and has concluded that it is consistent with applicable
policies in those guidelines.
J. Executive Order 13211
Executive Order 13211, ``Actions Concerning Regulations That
Significantly Affect Energy Supply, Distribution, or Use,'' 66 FR 28355
(May 22, 2001), requires Federal agencies to prepare and submit to OMB,
a Statement of Energy Effects for any proposed significant energy
action. A ``significant energy action'' is defined as any action by an
agency that promulgated or is expected to lead to promulgation of a
final rule, and that: (1) Is a significant regulatory action under
Executive Order 12866, or any successor order; and (2) is likely to
have a significant adverse effect on the supply, distribution, or use
of energy; or (3) is designated by the Administrator of OIRA as a
significant energy action. For any proposed significant energy action,
the agency must give a detailed statement of any adverse effects on
energy supply, distribution, or use should the proposal be implemented,
and of reasonable alternatives to the action and their expected
benefits on energy supply, distribution, and use. Today's regulatory
action to amend the test procedure for measuring the energy efficiency
of fluorescent lamp ballasts is not a significant regulatory action
under Executive Order 12866. Moreover, it would not have a significant
adverse effect on the supply, distribution, or use of energy, nor has
it been designated as a significant energy action by the Administrator
of OIRA. Therefore, it is not a significant energy action, and,
accordingly, DOE has not prepared a Statement of Energy Effects.
K. Executive Order 12630
Pursuant to Executive Order 12630, ``Governmental Actions and
Interference with Constitutionally Protected Property Rights,'' 53 FR
8859 (March 15, 1988), DOE has determined that this rule would not
result in any takings that might require compensation under the Fifth
Amendment to the United States Constitution.
L. Section 32 of the Federal Energy Administration Act of 1974
Under section 301 of the Department of Energy Organization Act
(Pub. L. 95-91; 42 U.S.C. 7101), DOE must comply with section 32 of the
Federal Energy Administration Act of 1974, as amended by the Federal
Energy Administration Authorization Act of 1977. (15 U.S.C. 788; FEAA)
Section 32 essentially provides in relevant part that, where a proposed
rule authorizes or requires use of commercial standards, the notice of
proposed rulemaking must inform the public of the use and background of
such standards. In addition, section 32(c) requires DOE to consult with
the Attorney General and the Chairman of the Federal Trade Commission
(FTC) concerning the impact of the commercial or industry standards on
competition. The proposed rule incorporates testing methods contained
in the following commercial standards: ANSI C82.2-2002, Method of
Measurement of Fluorescent Lamp Ballasts. While today's proposed test
[[Page 14312]]
procedure is not exclusively based on ANSI C82.2-2002, one component of
the test procedure, namely measurement of ballast factor, adopts a
measurement technique from ANSI C82.2-2002 without amendment. The
Department has evaluated these standards and is unable to conclude
whether they fully comply with the requirements of section 32(b) of the
FEAA, (i.e., that they were developed in a manner that fully provides
for public participation, comment, and review). DOE will consult with
the Attorney General and the Chairman of the FTC concerning the impact
of these test procedures on competition, prior to prescribing a final
rule.
V. Public Participation
A. Attendance at Public Meeting
The time, date and location of the public meeting are listed in the
DATES and ADDRESSES sections at the beginning of this NOPR. To attend
the public meeting, please notify Ms. Brenda Edwards at (202) 586-2945.
As explained in the ADDRESSES section, foreign nationals visiting DOE
headquarters are subject to advance security screening procedures.
B. Procedure for Submitting Requests To Speak
Any person who has an interest in the topics addressed in this
notice, or who is a representative of a group or class of persons that
has an interest in these issues, may request an opportunity to make an
oral presentation at the public meeting. Such persons may hand-deliver
requests to speak to the address shown in the ADDRESSES section at the
beginning of this notice between 9 a.m. and 4 p.m., Monday through
Friday, except Federal holidays. Requests may also be sent by mail or
e-mail to: Ms. Brenda Edwards, U.S. Department of Energy, Building
Technologies Program, Mailstop EE-2J, 1000 Independence Avenue, SW.,
Washington, DC 20585-0121, or [email protected]. Persons who
wish to speak should include in their request a computer diskette or CD
in WordPerfect, Microsoft Word, PDF, or text (ASCII) file format that
briefly describes the nature of their interest in this rulemaking and
the topics they wish to discuss. Such persons should also provide a
daytime telephone number where they can be reached.
DOE requests that those persons who are scheduled to speak submit a
copy of their statements at least one week prior to the public meeting.
DOE may permit any person who cannot supply an advance copy of this
statement to participate, if that person has made alternative
arrangements with the Building Technologies Program in advance. When
necessary, the request to give an oral presentation should ask for such
alternative arrangements.
C. Conduct of Public Meeting
DOE will designate a DOE official to preside at the public meeting
and may also employ a professional facilitator to aid discussion. The
public meeting will be conducted in an informal, conference style. The
meeting will not be a judicial or evidentiary public hearing, but DOE
will conduct it in accordance with section 336 of EPCA (42 U.S.C.
6306). There shall not be discussion of proprietary information, costs
or prices, market share, or other commercial matters regulated by U.S.
anti-trust laws.
DOE reserves the right to schedule the order of presentations and
to establish the procedures governing the conduct of the public
meeting. A court reporter will record the proceedings and prepare a
transcript.
At the public meeting, DOE will present summaries of comments
received before the public meeting, allow time for presentations by
participants, and encourage all interested parties to share their views
on issues affecting this rulemaking. Each participant may present a
prepared general statement (within time limits determined by DOE)
before the discussion of specific topics. Other participants may
comment briefly on any general statements. At the end of the prepared
statements on each specific topic, participants may clarify their
statements briefly and comment on statements made by others.
Participants should be prepared to answer questions from DOE and other
participants. DOE representatives may also ask questions about other
matters relevant to this rulemaking. The official conducting the public
meeting will accept additional comments or questions from those
attending, as time permits. The presiding official will announce any
further procedural rules or modification of procedures needed for the
proper conduct of the public meeting.
DOE will make the entire record of this proposed rulemaking,
including the transcript from the public meeting, available for
inspection at the U.S. Department of Energy, 6th Floor, 950 L'Enfant
Plaza, SW., Washington, DC 20024, (202) 586-2945, between 9 a.m. and 4
p.m., Monday through Friday, except Federal holidays. The official
transcript will also be posted on the Web page at http://www1.eere.energy.gov/buildings/appliance_standards/residential/fluorescent_lamp_ballasts.html.
D. Submission of Comments
DOE will accept comments, data, and information regarding the
proposed rule no later than the date provided at the beginning of this
notice. Comments, data, and information submitted to DOE's e-mail
address for this rulemaking should be provided in WordPerfect,
Microsoft Word, PDF, or text (ASCII) file format. Stakeholders should
avoid the use of special characters or any form of encryption, and
wherever possible, comments should include the electronic signature of
the author. Comments, data, and information submitted to DOE via mail
or hand delivery/courier should include one signed paper original. No
telefacsimiles (faxes) will be accepted.
According to 10 CFR 1004.11, any person submitting information that
he or she believes to be confidential and exempt by law from public
disclosure should submit two copies: one copy of the document including
all the information believed to be confidential, and one copy of the
document with the information believed to be confidential deleted. DOE
will make its own determination as to the confidential status of the
information and treat it according to its determination.
Factors of interest to DOE when evaluating requests to treat
submitted information as confidential include: (1) A description of the
items; (2) whether and why such items are customarily treated as
confidential within the industry; (3) whether the information is
generally known by or available from other sources; (4) whether the
information has previously been made available to others without
obligation concerning its confidentiality; (5) an explanation of the
competitive injury to the submitting person which would result from
public disclosure; (6) a date upon which such information might lose
its confidential nature due to the passage of time; and (7) why
disclosure of the information would be contrary to the public interest.
E. Issues on Which DOE Seeks Comment
Although comments are welcome on all aspects of this rulemaking,
DOE is particularly interested in receiving comments and views of
interested parties concerning the following issues:
1. All Aspects of the Existing Test Procedure for Active Mode Energy
Consumption
DOE invites comment on all aspects of the existing test procedure
for fluorescent lamp ballasts for active
[[Page 14313]]
mode energy consumption that appear at 10 CFR part 430, subpart B,
appendix Q (``Uniform Test Method for Measuring the Energy Consumption
of Fluorescent Lamp Ballasts'').
2. Appropriate Usage of ANSI Standards
DOE seeks comment on the appropriate use of ANSI C82.2-2002, ANSI
C82.11 Consolidated-2002, and ANSI C82.1-2004. See section III.E.3 for
further detail.
3. Method of Measurement for Dimming Ballasts
DOE seeks comment on potential methods of measurement to determine
the efficiency of dimming ballasts if DOE decides to include them in
the scope of energy conservation standards. See section III.F.2 for
further detail.
4. Resistor-Based Ballast Efficiency Test Method
DOE seeks comment on the effectiveness of the proposed resistor-
based BE test method and its expected improvement in measurement
variation. See section III.E.1 for further details.
5. Alternative Approaches To Amending the Test Procedure
DOE seeks comment from interested parties who do not support the
proposed resistor-based ballast efficiency method on the lamp-based BE
method and the light-output-based and RSE test procedures (see sections
III.E.2, III.E.3, and III.E.4 for further detail), or any other
procedure they believe is appropriate.
6. Ballasts That Do Not Operate Resistors
DOE seeks comment on why some ballasts do not operate when
connected to a resistor load bank and DOE's proposal to measure BEF
directly (as a light output measurement) for these ballasts. DOE
invites comment on other approaches to test these ballasts. See section
III.F.8 for further detail.
7. Ballast Factor Variation Due to Variations in Measured Lamp Power
DOE recognizes that in order to correlate measured BE to BEF using
DOE's proposed test procedure, the BF of the test ballast must be
determined. DOE seeks comment on DOE's approach to use light output-
based measurement to determine ballast factor and the resulting
variation in ballast factor due to lamp manufacturing variations. DOE
also requests comment on impact of this variation in BF on the
calculated BEF (according to the proposed test procedure). See section
III.F.3 for further detail.
8. Ballast Factor Binning
DOE seeks comment on the effect of DOE's approach of using a single
resistor value for measuring ballasts of all ballast factors (for a
particular ballast) and correlating measured BE to correlated BEF using
transfer equations specific to ballast factor bins. See section III.F.5
for further detail.
9. Transfer Equations
DOE seeks comment on the transfer equations developed to convert BE
to BEF. See section III.F.5 for further detail.
10. Scaling Transfer Equations
DOE seeks comment on the transfer equation scaling techniques
(across number of lamps operated by a ballast, starting method, ballast
factor, and total rated lamp power) used for product classes in which
there was insufficient correlation in the test data to establish a
slope. See section III.F.6 for further detail.
11. Burden on Manufacturers and Testing Facilities
DOE seeks comment on its assessment of the anticipated burden
imposed by the proposed test method. See section III.G for further
detail.
VI. Approval of the Office of the Secretary
The Secretary of Energy has approved publication of this proposed
rule.
List of Subjects in 10 CFR Part 430
Administrative practice and procedure, Confidential business
information, Energy conservation, Household appliances, Imports,
Incorporation by reference, Intergovernmental relations, Small
businesses.
Issued in Washington, DC on February 12, 2010.
Cathy Zoi,
Assistant Secretary, Energy Efficiency and Renewable Energy.
For the reasons stated in the preamble, DOE is proposing to amend
Part 430 of Chapter II of Title 10, Code of Federal Regulations as set
forth below:
PART 430-ENERGY CONSERVATION PROGRAM FOR CONSUMER PRODUCTS
1. The authority citation for Part 430 continues to read as
follows:
Authority: 42 U.S.C. 6291-6309; 28 U.S.C. 2461 note.
2. Section 430.3 is amended by:
a. Amending paragraphs (c)(5), (c)(7) and (c)(11) by adding at the
end of the paragraphs the words ``and Appendix Q1 of subpart B''.
b. Redesignating paragraphs (c)(11) as (c)(12); (c)(12) as (c)(15);
and (c)(13) as (c)(16).
c. Adding new paragraphs (c)(11), (c)(13) and (c)(14).
These revisions and additions read as follows:
Sec. 430.3 Materials incorporated by reference.
* * * * *
(c) * * *
(11) ANSI C82.1-2004, Revision of ANSI C82.1-1997 (``ANSI C82.1''),
American National Standard for Lamp Ballast--Line-Frequency Fluorescent
Lamp Ballast, approved November 19, 2004; IBR approved for Appendix Q
of subpart B and Appendix Q1 of subpart B.
* * * * *
(13) ANSI C82.11-2002, Revision of ANSI C82.11-1993 (``ANSI
C82.11''), American National Standard for Lamp Ballasts--High-frequency
Fluorescent Lamp Ballasts, approved January 17, 2002; IBR approved for
Appendix Q of subpart B and Appendix Q1 of subpart B.
(14) ANSI C82.13-2002 (``ANSI C82.13''), American National Standard
for Lamp Ballasts--Definitions for Fluorescent Lamps and Ballasts,
approved July 23, 2002; IBR approved for Appendix Q of subpart B and
Appendix Q1 of subpart B.
* * * * *
3. Section 430.23 is amended by revising paragraph (q) to read as
follows:
Sec. 430.23 Test procedures for the measurement of energy and water
consumption.
* * * * *
(q) Fluorescent Lamp Ballasts. (1) The Estimated Annual Energy
Consumption (EAEC) for fluorescent lamp ballasts, expressed in
kilowatt-hours per year, shall be the product of:
(i) The input power in kilowatts as determined in accordance with
section 3.1.3.1 of appendix Q to this subpart before the compliance
date of the amended standards for fluorescent lamp ballasts or section
7.1.2.2 of appendix Q1 to this subpart beginning on the compliance date
of the amended standards for fluorescent lamp ballasts; and
(ii) The representative average use cycle of 1,000 hours per year,
the resulting product then being rounded off to the nearest kilowatt-
hour per year.
(2) Ballast Efficacy Factor (BEF) shall be as determined in section
4.2 of appendix Q of this subpart before the compliance date of the
amended
[[Page 14314]]
standards for fluorescent lamp ballasts or section 8.3 of appendix Q1
to this subpart beginning on the compliance date of the amended
standards for fluorescent lamp ballasts.
(3) The Estimated Annual Operating Cost (EAOC) for fluorescent lamp
ballasts, expressed in dollars per year, shall be the product of:
(i) The representative average unit energy cost of electricity in
dollars per kilowatt-hour as provided by the Secretary,
(ii) The representative average use cycle of 1,000 hours per year,
and
(iii) The input power in kilowatts as determined in accordance with
section 3.1.3.1 of appendix Q to this subpart before the compliance
date of the amended standards for fluorescent lamp ballasts or section
7.1.2.2 of appendix Q1 to this subpart beginning on the compliance date
of the amended standards for fluorescent lamp ballasts, the resulting
product then being rounded off to the nearest dollar per year.
(4) Standby power consumption of certain fluorescent lamp ballasts
shall be measured in accordance with section 3.2 of appendix Q to this
subpart.
* * * * *
4. Appendix Q to Subpart B of Part 430 is amended by:
a. Adding introductory text.
b. Revising sections 1.15, 1.16, and 1.17.
c. Removing section 2.1, redesignating section 2.2 as section 2,
and revising redesignated section 2.
d. Redesignating sections 3.1, 3.2, 3.3, 3.3.1, 3.3.2, 3.3.3, 3.4,
3.4.1, and 3.4.2 as sections 3.1.1, 3.1.2, 3.1.3, 3.1.3.1, 3.1.3.2,
3.1.3.3, 3.1.4, 3.1.4.1, and 3.1.4.2, respectively.
e. Revising redesignated sections 3.1.1, 3.1.2, 3.1.3.1, 3.1.3.2,
3.1.3.3, 3.1.4.1, and 3.1.4.2.
f. Redesignating sections 3.5, 3.5.1, 3.5.2, 3.5.3, 3.5.3.1,
3.5.3.2, 3.5.3.3, and 3.5.3.4 as sections 3.2, 3.2.2, 3.2.3, 3.2.4,
3.2.4.1, 3.2.4.2, 3.2.4.3, and 3.2.4.4, respectively.
g. Adding sections 3.1 and 3.2.1.
h. Revising section 4.
These revisions and additions read as follows:
Appendix Q to Subpart B of Part 430--Uniform Test Method for Measuring
the Energy Consumption of Fluorescent Lamp Ballasts
Appendix Q is effective until the compliance date of the amended
standards for fluorescent lamp ballasts. After this date, all
fluorescent lamp ballasts shall be tested using the provisions of
Appendix Q1 except where Appendix Q1 specifies use Appendix Q for
testing certain ballasts that do not operate resistors.
* * * * *
1. Definitions
* * * * *
1.15 Power Factor means the power input divided by the product
of ballast input voltage and input current of a fluorescent lamp
ballast, as measured under test conditions specified in ANSI C82.2-
2002 (incorporated by reference; see Sec. 430.3).
1.16 Power input means the power consumption in watts of a
ballast an fluorescent lamp or lamps, as determined in accordance
with the test procedures specified in ANSI C82.2-2002 (incorporated
by reference; see Sec. 430.3).
1.17 Relative light output means the light output delivered
through the use of a ballast divided by the light output of a
reference ballast, expressed as a percent, as determined in
accordance with the test procedures specified in ANSI C82.2-2002
(incorporated by reference; see Sec. 430.3).
* * * * *
2. Test Conditions
The measurement of standby mode power need not be performed to
determine compliance with energy conservation standards for
fluorescent lamp ballasts at this time. The above statement will be
removed as part of a rulemaking to amend the energy conservation
standards for fluorescent lamp ballasts to account for standby mode
energy consumption, and the following shall apply on the compliance
date for such requirements. The test conditions for testing
fluorescent lamp ballasts shall be done in accordance with ANSI
C82.2-2002 (incorporated by reference; see Sec. 430.3). Any
subsequent amendment to this standard by the standard setting
organization will not affect the DOE test procedures unless and
until amended by DOE. The test conditions for measuring active mode
energy consumption are described in sections 4, 5, and 6 of ANSI
C82.2-2002. The test conditions for measuring standby power are
described in sections 5, 7, and 8 of ANSI C82.2-2002. Fluorescent
lamp ballasts that are capable of connections to control devices
shall be tested with all commercially available compatible control
devices connected in all possible configurations. For each
configuration, a separate measurement of standby power shall be made
in accordance with section 4 of the test procedure.
3. * * *
3.1 Active Mode Energy Efficiency Measurement
3.1.1 The test method for testing the active mode energy
efficiency of fluorescent lamp ballasts shall be done in accordance
with ANSI C82.2-2002 (incorporated by reference; see Sec. 430.3).
Where ANSI C82.2-2002 references ANSI C82.1-1997, the operator shall
use ANSI C82.1 (incorporated by reference; see Sec. 430.3) for
testing low-frequency ballasts and ANSI C82.11 (incorporated by
reference; see Sec. 430.3) for high-frequency ballasts.
3.1.2 Instrumentation. The instrumentation shall be as specified
by sections 5, 7, 8, and 15 of ANSI C82.2-2002 (incorporated by
reference; see Sec. 430.3).
3.1.3 * * *
3.1.3.1 Input Power. Measure the input power (watts) to the
ballast in accordance with ANSI C82.2-2002 (incorporated by
reference; see Sec. 430.3), section 4.
3.1.3.2 Input Voltage. Measure the input voltage (volts) (RMS)
to the ballast in accordance with ANSI C82.2-2002 (incorporated by
reference; see Sec. 430.3), section 3.2.1 and section 4.
3.1.3.3 Input Current. Measure the input current (amps) (RMS) to
the ballast in accordance with ANSI C82.2-2002 (incorporated by
reference; see Sec. 430.3), section 3.2.1 and section 4.
3.1.4 * * *
3.1.4.1 Measure the light output of the reference lamp with the
reference ballast in accordance with ANSI C82.2-2002 (incorporated
by reference; see Sec. 430.3), section 12.
3.1.4.2 Measure the light output of the reference lamp with the
test ballast in accordance with ANSI C82.2-2002 (incorporated by
reference; see Sec. 430.3), section 12.
3.2. * * *
3.2.1 The test for measuring standby mode energy consumption of
fluorescent lamp ballasts shall be done in accordance with ANSI
C82.2-2002 (incorporated by reference; see Sec. 430.3).
* * * * *
4. Calculations
4.1 Calculate Relative Light Output
[GRAPHIC] [TIFF OMITTED] TP24MR10.006
Where:
Photocell output of lamp on test ballast is determined in accordance
with section 3.1.4.2, expressed in watts, and
Photocell output of lamp on ref. ballast is determined in accordance
with section 3.1.4.1, expressed in watts.
4.2 Determine the Ballast Efficacy Factor (BEF) Using the Following
Equations
(a) Single lamp ballast.
[[Page 14315]]
[GRAPHIC] [TIFF OMITTED] TP24MR10.007
(b) Multiple lamp ballast.
[GRAPHIC] [TIFF OMITTED] TP24MR10.008
Where:
Input power is determined in accordance with section 3.1.3.1,
Relative light output as defined in section 4.1, and
Average relative light output is the relative light output, as
defined in section 4.1, for all lamps, divided by the total number
of lamps.
4.3 Determine Ballast Power Factor (PF)
[GRAPHIC] [TIFF OMITTED] TP24MR10.009
Where:
Input power is as defined in section 3.1.3.1,
Input voltage is determined in accordance with section 3.1.3.2,
expressed in volts, and
Input current is determined in accordance with section 3.1.3.3,
expressed in amps.
5. Appendix Q1 is added to Subpart B of Part 430 to read as
follows:
Appendix Q1 to Subpart B of Part 430--Uniform Test Method for Measuring
the Energy Consumption of Fluorescent Lamp Ballasts
Appendix Q1 is effective on the compliance date of the amended
standards for fluorescent lamp ballasts. Prior to this date, all
fluorescent lamp ballasts shall be tested using the provisions of
Appendix Q.
1. If the operator determines that a ballast does not operate a
resistor load bank, then the operator should use the test procedure
described in Appendix Q to Subpart B of Part 430. To determine that
a ballast does not operate a resistor load bank, the input power,
voltage, or current to the ballast should equal zero when tested in
accordance with this Appendix Q1 to Subpart B of Part 430.
2. Where ANSI C82.2-2002 (incorporated by reference; see Sec.
430.3) references ANSI C82.1-1997, the operator shall use ANSI C82.1
(incorporated by reference; see Sec. 430.3) for testing low-
frequency ballasts and shall use ANSI C82.11 (incorporated by
reference; see Sec. 430.3) for high-frequency ballasts.
3. Definitions
3.1. Commercial ballast is a fluorescent lamp ballast that is
not a residential ballast as defined in Section 3.8 and meets
technical standards for non-consumer RF lighting devices as
specified in subpart C of 47 CFR part 18.
3.2. Electrode heating refers to power delivered to the lamp by
the ballast for the purpose of raising the temperature of the lamp
electrode or filament. ANSI standards generally refer to this
process as cathode heating.
3.3. High-frequency ballast is as defined in ANSI C82.13
(incorporated by reference; see Sec. 430.3).
3.4. Instant-start is the starting method used instant-start
systems as defined in ANSI C82.13 (incorporated by reference; see
Sec. 430.3).
3.5. Low-frequency ballast is a fluorescent lamp ballast that
operates at a supply frequency of 50 to 60 Hz and operates the lamp
at the same frequency as the supply.
3.6. Programmed-start is the starting method used in programmed
start systems as defined in ANSI C82.13 (incorporated by reference;
see Sec. 430.3).
3.7. Rapid-start is the starting method used in rapid-start type
systems as defined in ANSI C82.13 (incorporated by reference; see
Sec. 430.3).
3.8. Residential ballast is a fluorescent lamp ballast designed
and labeled for use in residential applications. Residential
ballasts must meet the technical standards for consumer RF lighting
devices as specified in subpart C of 47 CFR part 18.
3.9. Resistor load bank means a network of resistors used to
model the load placed on a fluorescent lamp ballast by a fluorescent
lamp.
3.10. RMS is the root mean square of a varying quantity.
4. Instruments
4.1. All instruments shall be as specified by ANSI C82.2-2002
(incorporated by reference; see Sec. 430.3).
4.2. Power Analyzer. In addition to the specifications in ANSI
C82.2-2002 (incorporated by reference; see Sec. 430.3), the power
analyzer shall have a maximum 100 pF capacitance to ground and
frequency response between 40 Hz and 1 MHz.
4.3. Current Probe. In addition to the specifications in ANSI
C82.2-2002 (incorporated by reference; see Sec. 430.3), the current
probe shall be galvanically isolated and have frequency response
between 40 Hz and 20 MHz.
5. Test Setup
5.1. The ballast shall be connected to a main power source and
to the resistor load bank according to the manufacturer's wiring
instructions. Where the wiring diagram indicates connecting the
ballast lead to a lamp, the lead should be connected to a resistor
load bank.
5.1.1. Figures 1 and 2 illustrate the resistor load bank used to
model one fluorescent lamp. The four resistors labeled as
R1/2E represent the electrodes, and Rarc
represents the lamp arc.
5.1.2. Wire lengths between the ballast and resistor load bank
shall be the length provided by the ballast manufacturer.
5.2. A ballast shall be tested using one resistor load bank to
simulate one lamp. A ballast shall be connected to the number of
resistor load banks equal to the maximum number of lamps a ballast
is designed to operate.
5.3. A ballast designed to operate a lamp at high-frequency (as
defined in section 3.3) shall use a resistor with resistance that
simulates high-frequency operation. A ballast designed to operate a
lamp a low-frequency (as defined in section 3.5) shall use a
resistor with resistance that simulates low-frequency operation.
5.4. A ballast shall be tested with a resistor load bank with
the resistances indicated in Table A.
5.5. Power Analyzer
5.5.1. The power analyzer shall have n+1 channels where n is the
number of lamps a ballast operates.
5.5.2. Output Voltage. Leads from the power analyzer should
attach to each resistor load bank according to Figure 1 for rapid-
and programmed-start ballasts and Figure 2 for instant-start
ballasts.
5.5.3. Output Current. A current probe shall be positioned on
each resistor load bank according to Figure 1 for rapid- and
programmed-start ballasts and Figure 2 for instant-start ballasts.
Table A--Simulated Lamp Resistor Values
--------------------------------------------------------------------------------------------------------------------------------------------------------
Low-frequency High-frequency
operation resistance operation resistance
Nominal (Ohms) (Ohms)
Ballast type lamp Lamp diameter and base -----------------------------------------------
wattage Electrode Lamp arc Electrode Lamp arc
(R1/2E) (Rarc) (R1/2E) (Rarc)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Ballasts that operate one, two, three, four, five, or six 32 T8 MBP........................... 5.75 439 5.75 760
straight-shaped lamps (commonly referred to as 4-foot 34 T12 MBP.......................... 4.8 151 4.8 204
medium bipin lamps) with medium bipin bases, a nominal
overall length of 48 inches, a rated wattage of 25W or
more, and an input voltage at or between 120V and 277V.
[[Page 14316]]
Ballasts that operate one, two, three, four, five, or six 32 T8 MBP........................... 5.75 439 5.75 760
U-shaped lamps (commonly referred to as 2-foot U-shaped 34 T12 MBP.......................... 4.8 151 4.8 204
lamps) with medium bipin bases, a nominal overall length
between 22 and 25 inches, a rated wattage of 25W or
more, and an input voltage at or between 120V and 277V.
Ballasts that operate one or two rapid-start lamps 86 T8 HO RDC........................ N/A N/A 4.75 538
(commonly referred to as 8-foot high output lamps) with 95 T12 HO RDC....................... 1.6 131 1.6 204
recessed double contact bases, a nominal overall length
of 96 inches and an input voltage at or between 120V and
277V.
Ballasts that operate one or two instant-start lamps 59 T8 slimline SP................... N/A* 876 N/A* 1256
(commonly referred to as 8-foot slimline lamps) with 60 T12 slimline SP.................. N/A* 313 N/A* 431
single pin bases, a nominal overall length of 96 inches,
a rated wattage of 52W or more, and an input voltage at
or between 120V and 277V.
Ballasts that operate one or two straight-shaped lamps 28 T5 Mini-BP....................... N/A N/A 20 950
(commonly referred to as 4-foot miniature bipin standard
output lamps) with miniature bipin bases, a nominal
length between 45 and 48 inches, a rated wattage of 26W
or more, and an input voltage at or between 120V and
277V.
Ballasts that operate one, two, three, or four straight- 54 T5 Mini-BP....................... N/A N/A 4 255
shaped lamps (commonly referred to as 4-foot miniature
bipin high output lamps) with miniature bipin bases, a
nominal length between 45 and 48 inches, a rated wattage
of 49W or more, and an input voltage at or between 120V
and 277V.
Ballasts that operate one, two, three, or four straight- 32 T8 MBP........................... 5.75 439 5.75 760
shaped lamps (commonly referred to as 4-foot medium 34 T12 MBP.......................... 4.8 151 4.8 204
bipin lamps) with medium bipin bases, a nominal overall
length of 48 inches, a rated wattage of 25W or more, an
input voltage at or between 120V and 277V, a power
factor of less than 0.90, and that are designed and
labeled for use in residential applications.
Ballasts that operate one, two, three, four, five, or six 86 T8 HO RDC........................ N/A N/A 4.75 538
rapid-start lamps (commonly referred to as 8-foot high 110 T12 HO RDC....................... 1.6 166 1.6 275
output lamps) with recessed double contact bases, a
nominal overall length of 96 inches, an input voltage at
or between 120V and 277V, and that operate at ambient
temperatures of 20 [deg]F or less and are used in
outdoor signs.
--------------------------------------------------------------------------------------------------------------------------------------------------------
MBP, Mini-BP, RDC, and SP represent medium bipin, miniature bipin, recessed double contact, and single pin, respectively.
* The resistor load bank representing 8-foot slimline single pin (SP) lamps does not have electrode resistors.
[[Page 14317]]
[GRAPHIC] [TIFF OMITTED] TP24MR10.004
6. Test Conditions
6.1. The test conditions for testing fluorescent lamp ballasts
shall be done in accordance with ANSI C82.2-2002 (incorporated by
reference; see Sec. 430.3). DOE further specifies that the
following revisions of the normative references indicated in ANSI
C82.2-2002) should be used in place of the references directly
specified in ANSI C82.2-2002: ANSI C78.81 (incorporated by
reference; see Sec. 430.3), ANSI C78.901 (incorporated by
reference; see Sec. 430.3), ANSI C82.1 (incorporated by reference;
see Sec. 430.3), ANSI C82.3 (incorporated by reference; see Sec.
430.3), ANSI C82.11 (incorporated by reference; see Sec. 430.3),
and ANSI C82.13 (incorporated by reference; see Sec. 430.3). All
other normative references shall be as specified in ANSI C82.2-2002.
6.2. Temperature Stabilization. Ballasts shall be thermally
conditioned for at least 4 hours at room temperature (25 2 [deg]C), with normal room or lab ventilation.
6.3. Input Voltage. The directions in ANSI C82.2-2002
(incorporated by reference; see Sec. 430.3) section 4.1 should be
ignored with the following directions for input voltage used
instead. For commercial ballasts capable of operating at multiple
voltages, the ballast shall be tested 277V 0.1%. For
ballasts designed and labeled for residential applications and
capable or operating at multiple voltages, the ballast shall be
tested at 120V 0.1%.
6.4. Duty Cycle. The duty cycle shall be no more than 50%. For
every operational minute, the resistor load bank shall be rested at
zero power for at least one minute.
7. Test Method
7.1. Ballast Efficiency
7.1.1. The ballast shall be connected to the appropriate
resistor load bank and to measurement instrumentation as indicated
by the Test Setup in section 5.
7.1.2. The ballast shall be operated for one minute followed by
an instantaneous data
[[Page 14318]]
capture of the parameters described in sections 7.1.2.1 through
7.1.2.4.
7.1.2.1. Output Power. The power analyzer shall calculate output
power by capturing voltage across each lamp arc resistor using the
setup described in 5.5.2 and current to the lamp according to the
setup described in 5.5.3 and summing the power for each lamp.
7.1.2.2. Input Power. Measure the input power (watts) to the
ballast in accordance with ANSI C82.2-2002 (incorporated by
reference; see Sec. 430.3), section 7.
7.1.2.3. Input Voltage. Measure the input voltage (volts) (RMS)
to the ballast in accordance with ANSI C82.2-2002 (incorporated by
reference; see Sec. 430.3), section 3.2.1 and section 4.
7.1.2.4. Input Current. Measure the input current (amps) (RMS)
to the ballast in accordance with ANSI C82.2-2002 (incorporated by
reference; see Sec. 430.3), section 3.2.1 and section 4.
7.2. Ballast Factor
7.2.1. ANSI C82.2-2002 (incorporated by reference; see Sec.
430.3) shall be further specified for the purpose of measuring
ballast factor by the following:
7.2.1.1. The reference lamp shall be operated at the specified
input voltage to the reference circuit.
7.2.1.2. Electrode heating shall be used in the reference
circuit for all ballasts that operate bipin (MBP, mini-BP) or
recessed double contact (RDC) lamps as indicated in Table A.
Electrode heating shall not be used in the reference circuit for
single pin lamps.
7.2.1.3. Light output measurements shall be used for all
ballasts, including instant-start ballasts. Power measurements shall
not be used.
7.2.2. Measure the light output of the reference lamp with the
reference ballast in accordance with ANSI C82.2-2002 (incorporated
by reference; see Sec. 430.3), section 12, using section 7.2.1 to
further specify ANSI C82.2-2002. The reference lamp shall have the
nominal wattage corresponding to the test ballast as indicated in
Table A.
7.2.3. Measure the light output of the reference lamp with the
test ballast in accordance with ANSI C82.2-2002 (incorporated by
reference; see Sec. 430.3), section 12, using section 7.2.1 to
further specify ANSI C82.2-2002 The reference lamp shall have the
nominal wattage corresponding to the test ballast as indicated in
Table A.
8. Calculations
8.1. Calculate Ballast Factor (BF)
[GRAPHIC] [TIFF OMITTED] TP24MR10.010
Where:
Photocell output of lamp on test ballast is determined in accordance
with section 7.2.2, expressed in watts, and
Photocell output of lamp on reference ballast is determined in
accordance with section 7.2.3, expressed in watts.
8.2. Calculate Ballast Efficiency (BE)
8.3. Calculate Ballast Efficacy Factor (BEF). Multiply BE by the
Appropriate Conversion Factor in Table B. BEF = Conversion Factor x
BE
Table B--Conversion Factor, BE to BEF
----------------------------------------------------------------------------------------------------------------
Number of lamps
Ballast and lamp type Starting Ballast -----------------------------------------------
method\*\ factor\**\ One Two Three Four Five Six
----------------------------------------------------------------------------------------------------------------
Four-Foot MBP, and Two-Foot U- IS and RS (not High........... 3.233 1.624 1.081 0.812 0.650 0.542
Shaped. PS). Normal......... 3.378 1.697 1.129 0.849 0.679 0.566
Low............ 3.430 1.723 1.147 0.862 0.690 0.575
----------------------------------------------------------------------------------
PS.............. High........... 3.204 1.610 1.071 0.808 0.644 0.537
Normal......... 3.348 1.682 1.119 0.844 0.673 0.561
Low............ 3.400 1.708 1.137 0.857 0.684 0.570
----------------------------------------------------------------------------------------------------------------
Four-Foot T5, MiniBP SO...... All............. High........... 2.910 1.584 ...... ...... ...... ......
Normal......... 3.041 1.655 ...... ...... ...... ......
Low............ 3.088 1.680 ...... ...... ...... ......
----------------------------------------------------------------------------------------------------------------
Four-Foot T5, MiniBP HO...... All............. All............ 1.703 0.927 0.649 0.504 ...... ......
----------------------------------------------------------------------------------------------------------------
Eight-Foot SP Slimline....... All............. High........... 1.653 0.841 ...... ...... ...... ......
Normal......... 1.727 0.878 ...... ...... ...... ......
Low............ 1.754 0.892 ...... ...... ...... ......
----------------------------------------------------------------------------------------------------------------
Eight-Foot RDC HO............ IS and RS (not All............ 1.128 0.614 ...... ...... ...... ......
PS).
----------------------------------------------------------------------------------
PS.............. All............ 1.138 0.619 ...... ...... ...... ......
----------------------------------------------------------------------------------------------------------------
Residential Ballast, Four- IS and RS (not All............ 3.357 1.686 1.122 0.853 ...... ......
Foot MBP, and Two-Foot U- PS).
Shaped.
----------------------------------------------------------------------------------
PS.............. All............ 3.328 1.671 1.113 0.846 ...... ......
----------------------------------------------------------------------------------------------------------------
Sign Ballast................. All............. All............ 0.888 0.483 0.338 0.263 0.216 0.184
----------------------------------------------------------------------------------------------------------------
\*\IS = Instant-start; RS = Rapid-start; PS = Programmed-start
\**\High ballast factor: BF >= 1.10; Normal ballast factor: 0.78 > BF >1.10; Low ballast factor: BF <= 0.78.
8.4. Calculate Power Factor (PF)
[[Page 14319]]
[GRAPHIC] [TIFF OMITTED] TP24MR10.011
Where:
Input power is determined in accordance with section 7.1.2.2,
Input voltage is determined in accordance with section 7.1.2.2, and
Input current is determined in accordance with section 7.1.2.3.
6. Section 430.62 is amended by revising paragraph (a)(1), and
adding new paragraphs (a)(4)(xxv) and (a)(6) to read as follows:
Sec. 430.62 Submission of data.
(a)(1) Except as provided in paragraph (a)(2) and (a)(6) of this
section, each manufacturer or private labeler before distributing in
commerce any basic model of a covered product subject to the applicable
energy conservation standard or water conservation standard (in the
case of faucets, showerheads, water closets, and urinals) set forth in
subpart C of this part shall certify by means of a compliance statement
and a certification report that each basic model(s) meets the
applicable energy conservation standard or water conservation standard
(in the case of faucets, showerheads, water closets, and urinals) as
prescribed in section 325 of the Act. The compliance statement, signed
by the company official submitting the statement, and the certification
report(s) shall be sent by certified mail to: Department of Energy,
Office of Energy Efficiency and Renewable Energy, Office of Codes and
Standards, Forrestal Building, 1000 Independence Avenue, SW.,
Washington, DC 20585-0121.
* * * * *
(4) * * *
(xxv) Fluorescent Lamp Ballasts, the ballast efficacy factor (BEF)
and the ballast power factor (PF).
* * * * *
(6) Each manufacturer or private labeler of a basic model of a
covered fluorescent lamp ballast shall file a compliance statement and
a certification report to DOE using the test procedure described in
Appendix Q to Subpart B of Part 430 within 1 year of publication of the
fluorescent lamp ballast test procedure and energy conservation
standard final rulemaking. Furthermore, each manufacturer or private
labeler of a basic model of a covered fluorescent lamp ballast shall
file a compliance statement and a certification report to DOE using the
test procedure described in Appendix Q1 to Subpart B of Part 430 before
within 4 years of publication of the fluorescent lamp ballast test
procedure and energy conservation standards final rulemaking.
* * * * *
[FR Doc. 2010-6374 Filed 3-23-10; 8:45 am]
BILLING CODE 6450-01-P